MeCCSA Response to Higher Education White Paper

MeCCSA’s response to the White Paper arises from a period of discussion and dialogue with members over the consultation period. Our response is divided into the following sections that reflect the key concerns of our members: Education vs. employability; Contestable Student Places; ‘Efficiency’ Savings; Education for sale and for profit; Micro-Management or Accountability?; Inequality; Employer Sponsorship; The Role of HEFCE.

Higher Education White Paper consultation
Higher Education Directorate
Department for Business, Innovation and Skills
1 Victoria Street
London SW1H 0ET

19 September 2011

MeCCSA submission to Consultation on Higher Education White Paper

Background note

This Association represents teachers, researchers, and students in its fields within UK Higher Education, and has members across the sector, currently in 80 institutions.

Our response to the White Paper arises from a period of discussion and dialogue with members over the consultation period. Our response is divided into the following sections that reflect the key concerns of our members.

General comments

The removal of the block teaching grant to undergraduate courses in arts, humanities and social sciences (so-called Band C & D subjects) and reduced central funding to STEM subjects (science, technology, engineering and mathematics) by equivalent amounts dismantles the core teaching funding stream for England’s public universities, and represents a significant threat to the delivery of these courses. Each degree course will lose at least £3,670 per student per annum (2011/12 figures excluding London weighting), which means that a large proportion of the new 2012 fee levels will, at best, only replace lost public funding, and then only for fees in excess of £7,500.  Furthermore, in these unchartered waters and newly competitive terrain, resources will need to be diverted to marketing, recruitment and meeting the costs of regulatory compliance, rather than going into teaching that enhances the student experience.

Tuition fees will neither reduce the public funding deficit (HEPI, 2011) nor cover the cost of university provision of higher education if we wish to retain high-quality teaching and research alongside the contribution to local economic, civic and social life. A report by the New Economics Foundation states that, “Universities yield benefits way beyond the individual financial returns to students and human capital gains for the economy. We find that just three social outcomes – greater political interest, higher interpersonal trust and better health – contribute a benefit of £1.31 billion to UK society over and above the economic benefits” (2011: Degrees of Value: How Universities Benefit Society. Available at:  These benefits must be taken account of in the assessment of appropriate public funding.

In our own fields, graduates contribute to the growth of what have become central and vital features of social life and the economy in the UK and elsewhere, notably in the media, the ‘creative industries’, and elsewhere. Programmes taught by our members are among the most popular in UK universities, and are acknowledged internationally for their significance and impact, as was made evident at the last Research Assessment Exercise.   Any restriction in their growth or accessibility would not only diminish the impact of UK universities in central features of contemporary life and economy, but threaten the international reputation and attractiveness of  UK universities to international students and research funders.

Yet institutions such as LSE, Goldsmiths and the University of the Arts London, will receive no block teaching grant at all as they only offer Band C & D subjects. The speed with which these profound changes to university financing are implemented will create huge instability across the sector. Many institutions are required to replace entirely their annual grant income of £35 million (or more) with private fee income within three years in an unknown and insecure marketplace.

This makes little sense particularly in the grip of a recession when graduates are particularly required, and University offers a means to avoid unemployment while gaining vital skills. The higher education sector appears to be taking the biggest hit in public spending cuts of all public sectors. While Germany, France and the USA have all pumped additional funding into higher education as part of their economic recovery programmes, the UK has done precisely the opposite. Britain is falling behind other industrialised nations in the race to produce the highly skilled graduates needed to remain competitive in the world economy. In 2000 37 percent of Britons graduated, ranking Britain third amongst the members of the OECD, beaten only by Finland and New Zealand. But by 2008 Britain had fallen to 14th, overtaken by countries with rising graduation rates, such as Poland, the Netherlands, Japan, Ireland and Norway, (OECD annual review of education statistics, 2010). The same OECD report said investing in higher education made financial sense for countries, even if they were running a deficit, as it enabled them to maintain a highly skilled workforce with graduates on average paying back threefold in taxes and other benefits the public cost of their education.

The purpose of the White Paper seems to be to try and manage the financial mess that the massive hike in student fees and scrapping of the block teaching grant for arts, humanities, and social sciences left us with.  A market system that has encouraged the majority to charge the maximum fee (otherwise by market definition they must be worthless), that would result in many students never paying back the full cost of their fees, has meant that student numbers need to be controlled and high earnings encouraged (as a student begins to pay back their loans when they reach the earning threshold of £21,000) for the system to  be even vaguely workable.

We support the view expressed in the report by the Higher Education Policy Institute (2011: para 54) that states, “The government’s entire economic strategy is based around reducing public borrowing. Borrowing to give grants to universities counts as public borrowing. Borrowing in order to make loans to students does not count as public borrowing, to the extent that the government can show a stream of income to offset the loans. It is smoke and mirrors, and it provides an extraordinary reason for changing the whole basis for the financing and organisation of the university system.”

Furthermore, the basis of fee repayment is far from progressive. The suggestion that those who are in a position to (i.e. are more wealthy) can pay back the cost of tuition fees upfront thereby avoiding the Resource Account Budgeting (RAB) charge means that the less well off end up paying substantially more over time (HEPI, 2011). HEPI (2011: 6) also estimate the actual costs to the public purse as £2.1 billion costs on the assumption that fees less waivers will, on average, be set at £7500. “If they are higher than this, the total debts will be higher as will the RAB charge, as more former students will fail to repay their loans in full” (HEPI, 2011, Para 16).  The underlying argument that higher incomes resulting from a university education should be repaid by additional taxation while higher incomes accrued without such education do not, is inequitable and illogical.

Education vs. employability

Universities are central to the cultural and civic life of the country. This is particularly true of the courses provided by our members; courses that question and investigate the social and cultural fabric of our lives while also supporting directly and indirectly the creative and cultural industries.   The Government fails to support these dual aims preferring instead to prioritize the importance of some professional and vocational courses. We believe all courses have a core value to society that reaches way beyond education as ‘training for employment’ and all universities as training providers. This focus distorts the breadth of courses within higher education and undermines, with unknown but potentially profound human cost, the important social and cultural mission of the public university.

The arts, humanities and social sciences are fundamental for cultural innovation and fostering the public debate essential for a healthy democracy. The policies proposed in this White Paper will seriously diminish provision in these areas, except for a few ‘elite’ universities. Yet repeated public audit of the research and teaching quality associated with the range of subjects our members deliver has confirmed how wide a spread if institutions house excellence in both.  Thus any financial constraint aimed at or resulting in narrow concentration in very few institutions would restrict student choice and seriously depress the quality of research and teaching.  Commercial pressures have already led several universities to close courses such as philosophy, sociology, performing arts, history and classics.

Contestable Student Places

Competition is one of the key words in the White Paper: competition between institutions, between courses and between academics. Competition, we are told, will ‘protect the interests of students’ (WP p12). What this really means is that competition will drive down costs. There will be 85,000 contestable student places between institutions in 2012/13. That means 85,000 places removed from institutions and put into a ring for everyone to fight over. These will be made up of 20,000 places for institutions (including FE colleges and private providers) charging less than £7500 in fees who ‘combine good quality with value for money’ (WP p5) – in other words, those institutions most likely to attract students from less privileged backgrounds who, attracted by the lower fees, will be able to pile students high and stack them deep. The remaining 65,000 contestable places will be for the top achieving students who gain AAB or above at A Level, who have traditionally gone to elite institutions and include a high proportion of students from selective grammar schools and fee-paying schools. These are also the students who are most likely, from their privileged starting point, to go into high earning jobs – and therefore pay back their loans quicker (and more cheaply). The 20,000 students going to the cheaper courses (and likely to come from less privileged backgrounds and less likely to be high earners) aren’t given any guarantee of going to the institution of their choice (see section on inequality below).

Similarly, the most selective institutions will be able to expand with relative ease, if space permits.  They may be competing with other institutions for the estimated 65,000 AAB+ students, but in reality their high prestige will limit the range of this competition with a very limited pool of institutions forming the institutions of choice of those with the highest grades.

Institutions outside of the Russell group are likely to try and attract AAB students with scholarships exclusively available to AAB students alone – they may, as a result retain these students but at high cost to the institution and at real detriment to those students from less privileged backgrounds who traditionally get less high A levels results but would benefit more from the limited number of scholarships and fee waivers available.

‘Efficiency’ Savings

Competition goes hand in hand with efficiency: ‘[w]e expect new courses to offer increased value for money’ (p7) and we are told that there is ‘room for further efficiency savings and institutions should be looking at ways they can save money’ (p17). They will be shown the way by new private providers with different business models who will have access to the government loans scheme. This is couched in terms of the private sector coming to the rescue of the public sector. It is not. Rather, the taxpayer is being forced to hand over money to the private sector with students bearing the brunt. So, institutions will apparently improve through competing on price. Translated into practice, efficiency gains often mean cutting costs through losing staff and increasing student numbers. The rich institutions with massive endowments, huge property portfolios and an elite student body from privileged backgrounds will continue relatively unscathed; the rest, who cater for the less privileged state-educated ‘masses’, will scramble around trying to survive. Bringing in bargain basement degree providers may take the pressure off the Treasury but it will drive a wedge of inequality between higher education providers and the students they attract.

This new and ‘improved’ education ‘market’ recognizes the various ‘non-traditional’ routes through which students come into higher education. Indeed there is, in the White Paper,  a whole chapter called ‘A Diverse and Responsive Sector’. But what it means is that new private companies, frequently referred to as  ‘alternative’, ‘non traditional’ and ‘other’ providers (p5), will enter the fray while further education colleges, who are able to offer courses at much lower costs, will be encouraged to free themselves from their dependence on universities when providing higher education.

Education for sale and for profit

This opens the English university system to the likes of Pearson and Apollo, organisations with a bottom line which is not about education but about making profits. While Apollo, which already runs the BPP Law School in the UK, is under investigation by US officials, a HEFCE report earlier this year talks of the ‘risks associated with an expansion of the role of private providers in higher education’ in focusing on only a narrow range of subjects and of presenting various difficulties concerning quality. It concludes that a rise in private providers ‘may amount to a reputational risk for UK higher education’.

The government believes that for-profit providers can bring the level of fees down to £6000. For this fee, the new for-profit providers will expect to pay profits to investors and owners whilst also maintaining a high advertising and marketing budget as they enter the market. They can only trim costs by having fewer and less qualified staff: off-the-shelf curriculum materials will be delivered by service teachers. This will likely damage higher education rather than enhance it.

Micro-Management or Accountability?

The deregulatory  (freeing up student numbers and relaxing rules on who is eligible to have degree-awarding powers) is combined with the re-regulatory. Cutting red tape is matched by micro-management of whether institutions are deemed to offer ‘good quality’ courses, are meeting access requirements and responding adequately to student complaints.  The White Paper states that government will ‘strip back excessive regulation on providers wherever it is possible including reducing burdens from information collection’ (p6) while also introducing the necessity for the collection of a whole raft of other data that will make up the Key Information Set (KIS). This will be based on the National Student Survey and other indicators which are currently published along with new categories: information on graduate salaries; information on teaching and learning methods and the balance of time between different activities; information on assessment methods; and information on students’ views of their Students’ Union.

In this spirit, student feedback is now to assume a much higher profile and public role. Student feedback has been taken seriously by the sector for many years but it is an internal process that encourages reflexivity and constructive practice that is monitored by internal and external teaching quality assessments. Insisting on the publication of feedback will induce a mechanistic model designed for a system that will skew the process towards gaining a competitive edge rather than promoting good pedagogy. It is a model that rewards ‘satisfaction’ over learning and assumes that the students, who are presumably taking a course because they don’t know  that particular subject, are best placed to criticize the content. While the National Student Survey gains in importance as the consumer guide to acquiring a degree it is all too easy to see how purchasing power can override pedagogic sense. The White Paper makes the mistake of treating everything that is paid for as a product, turning education simply into another commodity. You get to choose which product you are going to buy (if you are wealthy enough to find debt acceptable and lucky enough to have got high grades) and if it doesn’t deliver, then as a consumer you can kick up a fuss. So, the new loans regime will ‘put more power into the hands of students’ (p15); the new risk-based quality assurance regimes will give students ‘power to hold universities to account’ (p37) while more accurate data ‘will empower prospective students by ensuring much better information on different courses’ (p2).

Under the heading of ‘student engagement’ (WP 3.7) it is proposed that summaries of student evaluation of teaching surveys (SETs) on individual lecturers and modules should be published on universities’ websites to ‘inform student choice and stimulate competition between peers’ (WP 3.7). It is asserted that this will help ‘to drive an improvement in the quality of teaching’. Neither the White paper, nor the BIS supporting analysis provide evidence for this assertion, which makes a facile and tacit equivalence between satisfaction and popularity on the one hand with educational significance and effectiveness on the other.

In the UK, normal practice in HEIs is that student feedback on individual courses and lecturers is confidential to the person concerned and is sometimes shared with their line manager or used alongside peer observation and appraisal as part of professional development. Publishing module level student feedback could undermine established mechanisms of professional development and threaten teamwork and co-operation. It would also encourage a culture of ‘blame’ for lecturers when the problem is organisational or managerial.

Institutions will be required to provide ‘Key Information Sets’, but in the crucial aspects of prospective income and student satisfaction, this information is hardly fit for purpose since the data is highly unreliable and does not allow for comparison. Consequently it is more likely to give rise to mis-selling than to facilitate student choices.

Students are being encouraged to see a tripling of fees in terms of the quality of the product where quality is judged on immediate, measurable outcomes. Increasingly the faults students point to will be directed at the grades they are given and the jobs they get. This is entirely understandable in a situation where the need to get a high paid job to pay off the mountain of debt they are accumulating means anything less than a 2:1 does not represent value for money. Litigation by students will surge and the pressure on lecturers to play it safe and avoid the risks of being innovative or adventurous will be high. This is not about student power and it is certainly not about putting students at the heart of the system, it is about the privatisation of public institutions, and the emasculation of education. Universities are being encouraged to think and act like private providers of a commodity, and the White Paper is designed to facilitate a wholesale cultural shift in which all universities need to think of themselves now as part of a competitive marketplace. David Willetts made this perfectly clear in an interview on the day the white paper was published, insisting that universities must ‘not be in the mindset that they are part of the public sector’ (Today programme, 28 June). The net outcome will be a higher education system that has the private individual rather than the public good as its raison d’etre.


The difficulties of recruiting young people from disadvantaged backgrounds into higher education have been the subject of much debate and the focus of widening participation policies. As the White Paper acknowledges, in recent years there has been some progress towards reducing the participation gap between those from advantaged and disadvantaged areas studying for degrees.  However, the approach in the White Paper threatens to undermine this by creating a new alignment between universities charging the highest fees (£9,000) and independent and public schools that charge fees and have a higher percentage of students attaining AAB+. This will exacerbate the recruitment differential between them and students who have previously attended state secondary schools. This will deliver a double discrimination – a well resourced but small group of elite institutions that will charge £9,000 fees and swallow up all the elite AAB+ students to the detriment of all the rest thereby reinforcing established advantage and reducing competition. And although there are increased grants and maintenance loans for students from low income backgrounds, the proposal to offer ‘merit’ scholarships made without reference to need but on the level of entry qualifications gained to attract AAB+ students will further exacerbate this inequality in the system.

What is more, this appears to make little sense in the face of recent research reported by the Sutton Trust that states that students from state schools do better than those from private schools while at university. This is the case across the university system including the most selective universities:

“Comprehensive school pupils also performed better than their similarly qualified independent and grammar school counterparts in degrees from the most academically selective universities and across all degree classes, awarded to graduates in 2009.” (Sutton Trust, 3rd December 2010: outperform/)

Despite this, achievement at university is not part of government considerations to address issues of widening participation. The participation rate for disadvantaged young people at the more selective institutions has remained the same since 1994-95 (WP 5.6). While those from disadvantaged or less privileged backgrounds have weaker entry qualifications on average (HEPI, 2011) so long as institutions are not willing to make more use of contextual data, any increase in the difference in selectivity between institutions will further increase the social segregation and inequality. This is particularly true for mature students of whom only 1-2% have AAB+ qualifications. Giving HEIs the freedom to recruit an unlimited number of AAB+ students will make the threshold even more important and discourage institutions from selecting students more intelligently.

The introduction of the AAB+ threshold was designed to increase competition between institutions for these students, and as their non AAB+ quotas are cut, institutions will have to recruit more AAB+ students if they are to maintain their student numbers and continue to charge fees of more than £7500. This is likely to concentrate further the numbers of AAB+ students in institutions with high prestige and reputation and, as a consequence, reinforce the social segregation between groups of institutions. As the HEPI (2011) report notes this risk was identified in the BIS impact assessment but not in the equality impact assessment. The BIS impact assessment points out that others, including disabled students and BME students could be adversely affected (BIS 2011b: 71). The equality impact assessment only considers participation across the sector and so does not recognise this risk (BIS 2100e, paragraph 62). BME students are under represented in the most selective universities.

Those able to attract the ‘high achieving’ students will be free to charge the £9000 fee, whereas those dependent on the non-AAB+ quota would have to drop their net fees to £7500 to be able to bid for places, or reduce their headline fee to £6000 to be able to maintain their student numbers without going through an annual bidding process. A further 20,000 places are to be removed from existing recruitment caps across the sector and put out to tender to low cost institutions with consequent knock-on costs and risks of failure. The intention is that there will be a further shift of student places from core to margin in future years. Cheaper courses will run with less resources and are likely to attract students with lower entry qualifications from less advantaged backgrounds. Yet again, the disadvantaged will suffer a further disadvantage in the HEIs they can gain access to. It is those very universities that are faced with a reduction in fees that have been responsible for the recent advances in widening participation. In recruiting less well-prepared students, their teaching costs are higher, and under present arrangements they receive additional funding, which will continue.  However, this funding, which equates to about £400 per student, is less than the differences in recurrent income from £9000 maximum fee and the fees that the ‘wide participation’ universities will be allowed to charge.

There is no London weighting incorporated into the scheme, which means that universities in the capital face additional cost pressures as do students choosing to study in London.

So, even without consideration of the possible impact of higher fees – enhanced widening of participation is unlikely, given the constraints on numbers. In addition, there is a risk that the pattern of provision that comes out of the ‘core and margin’ system could be less attractive to the marginal entrant, that is the entrant for whom the pros and cons of further study are finely balanced. This too would work against making further progress in widening participation.

While quality is skewed by market principles, inequality is increased. Despite increased powers being given to OFFA and the requirements on institutions to meet benchmarks on widening participation – these measures remain sticking plasters on a seriously flawed system. The proposals in the White Paper are more likely to exacerbate inequalities between types of institutions and bring about a much closer correlation between the reputational hierarchy of universities and the social class of their student body.

Employer Sponsorship

The privatized and utilitarian approach to education gets a further push with ‘employer sponsorship’ of both students and courses (pp41-2) along with the sanctioning of employer and charity sponsorship for extra places outside the quota system. Essentially this means that employers can ‘kitemark’ degrees they respect. This puts a serious limitation on academic freedom. In the fields we are primarily concerned with we must seriously question the likelihood that external accreditation and engagement by major media or cultural corporations will enhance the diversity of content they would ’kitemark’ in degrees. Will the Murdoch Empire really be kitemarking degrees which criticise the free market, interrogate journalistic ethics or offer a positive assessment of trade unions? Will the Association of British Bankers put their stamp of approval on courses that put bankers under the spotlight? Higher education is at its best when it challenges orthodoxy, critiques power and offers students space to think critically. In the longer term the innovativeness, enterprising approach to thought and action, and imagination, that are not only essential to good pedagogy but to the contribution graduates make to society and the economy, will be driven out of the education they receive at university.

The Role of HEFCE

The largely independent regulator, HEFCE, is to become a ‘consumer champion for students and promoter of a competitive system’.  We would caution heavily against this approach and request that ministers think back to what happened to NHS reforms. After a huge public campaign, the role of the health regulator changed from one of promoting competition to a requirement to “support choice, collaboration and integration”. The role of HEFCE needs crucially to be the champion of Universities in the UK and not just a stick to hit them with.   It would be progressive and helpful to the country and the higher education within it if the funding council were to return to its former role, when as the UGC or UFC its function was to ensure the autonomy, quality,  and social constiruion of higher education rather than to align the sector’s provision with current ministerial priorities.


The brutal enforcement of market principles onto every aspect of higher education is a direct attack on equality and the value of public education for all. It is a turn away from equality of opportunity and a rush towards students as units of revenue and departments as profit centres. Our universities will increasingly be driven by purchase power rather than by who belongs in them or whom a public institution is meant to serve. We are particularly concerned that the proposals in the White Paper  will threaten the fields of media, communication and cultural studies that are rich, deep, broad and critical. Though already corporatized on many levels, universities are still public institutions and their arts, humanities and social science departments (where all aspects of such studies are found) are some of the last places which can challenge the principle that our lives can and should be ordered primarily by economic utility.

Education has a purpose that does not begin and end with a financial transaction based on fees and a student’s ability to pay or the possibility of shouldering a huge debt that is not common to all. Education should not be premised on economic utility above all else where the pursuit of profit is the only determinant of value. An approach that pivots on a purely economic principle—if I do this degree I will earn more—must be replaced with a new organizing ethos: if I do this degree I will learn more.

To these ends we support the call for:

  • Increase proportion of UK public expenditure devoted to higher education to at least the EU19 average of 1.1 per cent (up from 0.7 per cent) – a move that would bring in billions of pounds to the sector.
  • A commitment to staff/student ratios at the OECD average or better.
  • Restoration of maintenance grants and abolition of fees to be paid for through an increase in corporation tax and an increase to the top level of personal income tax.
  • Restoration of the block grant for all subjects. not least to ensure the healthy provision, diversity, and growth of areas we regard as essential for higher education as well as for the social, cultural and economic life of the nation in the fields we represent.
  • Where endowments are made, these should be taxed and the money redistributed to a central pot to pay for widening participation initiatives.


HEPI, (2011) The government’s proposals for higher education funding and student finance – an analysis, by John Thompson and Bahram Bekhradnia. Available at:’s-proposals-for-higher-education-funding-and-student-finance-–-an-analysis.html

OECD (2010) Annual Review of Statistics

New Economics Foundation (2008) University Challenge: Towards a well-being approach to quality in higher education.

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