Scottish Government

University of Glasgow response to Scottish Executive Consultation on the draft Student Fees (Specification) (Scotland) Order 2005

1. Thank you for your letter of 17 November consulting the University of Glasgow about this draft Order.

2. We have a number of comments at both policy and technical levels.

Policy

3. We are disappointed that the Executive has chosen to press ahead with this fees increase despite the strong trend of opinion, in response to the initial consultation, that the increases were premature until we had seen whether there really was a serious issue that needed addressed. We are also disappointed that the Executive has not responded to the strong trend of opinion which urged that, if fee increases were implemented, they were kept to the minimum level necessary to deliver the policy intention. The points made in our initial consultation response of 19 May (attached) still stand.

4. We are not persuaded that there is a significant problem of students from the rest of the UK potentially displacing suitably-qualified Scottish students. While we saw an increase of 734 in the number of rest-of-UK undergraduate applicants to the University of Glasgow between 04-05 and 05-06, many of these were considering us as a possibility among a range of universities throughout the UK. We actually offered 103 fewer unconditional offers to rest-of-UK students for 05-06 compared to 04-05, a decline of 16.5%. It may be prudent for you to look at admissions rather than applications data to see whether there is an emerging real-world problem. The UCAS data published on 19 January shows that the number of English students admitted to Scottish universities was up by only 220 students, while the number of Scottish -domiciled students admitted to English universities increased by 82. The net increase in English students' migration to Scotland was therefore only 138 students - less than one-third of one percent of all the students admitted Scottish institutions. The fall of 633 in the number of Scottish-domiciled students admitted to Scots universities therefore clearly cannot be attributed to the slight rise in admission of English students. Despite misleading media reporting, there is therefore no evidence yet of a significant displacement of Scottish students by English students at Scots universities.

5. We think it would be a great deal more prudent to increase tuition fees only in line with increase in the teaching unit of resource for 06-07, potentially making some increases beyond that in subsequent years if there proves to be a real-world problem. Leaping from £1,175 to £1,700 is a major step, and once the fee is set at £1,700 it is unlikely it will be reduced, and the Executive will not have benefited from the opportunity to adjust the scale of its action to the real scale of the issue. If the Executive judge that fees have to be increased now, we would advise strongly that they are increased experimentally in small increments, only increasing if the 'market', in terms of admissions of rest-of-UK students to Scots universities, is not stabilising to the degree that Scottish Ministers seek.

6. We recognise the 'special case' of medicine, though a fee of £2,700 is at the upper range of what we think is prudent to maintain Scottish universities' ability to attract the best students from across the UK, since in England many students will benefit from bursary assistance and other 'perks' paid for from the income of 'top-up fees'. We believe, as argued in our response to the initial consultation, that it is important to mitigate the increased fee for Scottish-domiciled students doing medicine as a second degree. This is an increasingly popular and appropriate career choice, enabling recruitment of more mature people with relevant first-degree qualifications into the medical profession, would effectively be blocked on the basis of cost for many students if they had to pay an annual fee of £2,700. While the letter from the Executive says that 'students who are not currently eligible for fee support from SAAS would pay a maximum of £1,200 under new arrangements, with the remainder paid by SAAS', we would welcome specific confirmation that Scottish-domiciled students pursuing medicine as a second degree would face a fee no higher than £1,200.

7. We welcome the lower increase in fees for part-time students, but the 'joined-up policy' of abolishing up-front fees for Scottish-domiciled part-time students has yet to be delivered.

8. If fees are to be increased in Scotland, we welcome the intention to introduce a fee waiver scheme for all UK students from low income families. However, we are not clear that the increased fees proposed for Scotland will enable a similar scale of assistance to be offered to students as those in England. In England, the requirement to set aside at least £300 of the £3,000 'top-up fee' to support wider access is a powerful instrument in redistributing support to students who might otherwise be discouraged from studying. OFFA's analysis of universities' access agreements south of the border shows that all universities are setting aside substantially more than £300 of the increased fee for bursaries and other forms of financial support, and that typically £600-900 of the increased fee will be used for student support. OFFA estimate that this will mean at least £300m of new support being available to students, with students from low income families typically benefiting by around £11,000 over 3 years. Will the scale of the Scottish scheme be comparable in scale? If so, how will it be funded? Will EU students also have a right to apply?

Technical

9. We do not see how the draft Order prevents the increased fees from applying to non-UK EU students, which we understand to be important to ensure the policy's compliance with European law.

10. We can see the logic of protecting existing students from the fees increase, but this is going to lead to complexity with the balance of funding between the Funding Council and SAAS being different between continuing and new students. For instance, within any particular cohort of students there may be:

• Scots-domiciled new undergraduates (£1,700 SAAS fee and corresponding reduction in SFC T-grant)
• Continuing Scots-domiciled students/ students who deferred entry (£1,200 SAAS fee and SFC T-grant at current levels plus programmed increases)
• Rest-of-UK new students, except as below (£1,700 self-funding, and corresponding reduction in SFC T-grant)
• Students transferring from rest-of-UK institutions, or deferred-entry rest-of-UK students (£1,200 self-funding and SFC T-grant at current levels plus programmed increases)
• Part-time students (£1,200 fee pro-rata, and SFC T-grant at current levels plus programmed increases)
• New Scottish medical first-degree students (£2,700 SAAS fee and corresponding reduction in SFC T-grant)
• Rest-of-UK medical students (£2,700 self-funding and corresponding reduction in SFC T-grant)
• Scots-domiciled students doing medicine as a second undergraduate degree (£1,200 self-funding, £1,500 SAAS fee, and corresponding reduction in SFC T-grant)
• Etc…

We urgently need to see from the Executive how this complexity will be managed by the Funding Council and SAAS in a way which does not disadvantage universities, i.e. we still receive the right amount of overall funding for each student even though the Funding Council contribution will be reduced for certain students. It appears to us to be practically impossible at this stage for the SFC to know what adjustments it should be making to T-grant for 2006-07 since it does not know what proportion of students, at which institutions and in which funded subject groups, will fall into the categories outlined above. A blanket reduction of SFC T-grant on the assumption that the balance will be made up through increases in SAAS fees and rest-of-UK students' own fees will lead to inequitable results, and overall financial losses to universities, because of the significant numbers of students who will be exempt from the proposed higher fees.

11. The proposed changes will also provide a further disincentive to the internationalisation of Scottish higher education. There is already a financial disincentive to accepting incoming ERASMUS students because we do not receive any SAAS fee for them. This disincentive will be increased as the fee becomes a higher proportion of the unit of teaching resource. If we are to deliver the commitment to internationalisation in the Minister's letter of guidance to the SFC we need to ensure that Univeristies are resourced to accept ERASMUS students at the same level of funding as they are resourced to accept other students, and at the very least that the proposed policy change does not lead to a further financial disincentive to these exchanges.

12. In relation to part-time students, we need to see demonstration of how the Executive and Funding Council will ensure that Universities are not disadvantaged. By default, the lowering of the SFC contribution per student will lead to a reduction in the funding we receive for part-time students, since it is not re-balanced by an increased fee from SAAS. This needs to be sorted.

13. Setting differential fees for students in different parts of the UK also raises practical difficulties about establishing a student's domicile for fees purposes, with the prospect of challenges and litigation against universities' decisions to put students into particular fees categories (or against the Executive itself for discriminatory pricing). For instance, is an 18 year old from England who has left the parental home, and who spends the majority of his or her time in Scotland, robustly categorisable as having a non-Scottish domicile? Why should an adult of any age be categorised on the basis of their parents' domicile? Is a 'mature' student who moves to Scotland at the same time as starting a course of study at a Scottish university Scottish-domiciled? These points are not clear, and give ample scope for the practicalities to undermine the policy.

14. There is also going to be a substantial burden for universities in managing such a complex system of different levels of SAAS funding, SFC funding and students' self-funding, requiring university administrations to distinguish which category a student falls into and ensure that the correct balance of funding is secured from SAAS, the SFC and students' own fees where appropriate. We cannot see that the costs of administering this complexity have been taken into account in the Regulatory Impact Assessment.

15. For budgeting purposes, we need to know the fees we will receive per student from SAAS (or from the student) by the time we receive the SFC's grant letter (around 18 March).

Alastair Sim

Director of Planning Services

University ofGlasgow

19 January 2005