WALES
CYMRU

RESPONSE TO: Welsh Government consultation: Part-time higher education funding including student finance 2012/13

Contact Details:

Lleu Williams
Political Liaison Officer
UCU
Unit 33, The Enterprise Centre 
Tondu
BRIDGEND
CF32 9BS

Tel: 01656 721951
E-mail: lwilliams@ucu.org.uk  

The University and College Union (UCU) represents more than 120,000 academics, lecturers, trainers, instructors, researchers, managers, administrators, computer staff, librarians and postgraduates in universities, colleges, prisons, adult education and training organisations across the UK.
UCU is the largest post-school union in the world: a force working for educators and education that employers and the government cannot ignore. 
It was formed on 1 June 2006 by the amalgamation of two strong partners - the Association of University Teachers (AUT) and NATFHE-the University & College Lecturers' Union - who shared a long history of defending and advancing educators' employment and professional interests.
UCU believes that access to part-time higher education is vital for many people in Wales, especially those from lower income backgrounds, those who are parents and those who are unable to access full time higher education for a number of other reasons. Part time education gives people from a wide variety of backgrounds to access higher education and study at a pace that is suitable to their home, work and personal life, which is essential if we are to remove all barriers for people to access higher education.
Part time education allows the individual to study in a flexible, bite-sized learning environment, as well as allowing the flexibility in changing skills which is good for employers and learners alike. UCU believes that these principles should be taken into consideration when deciding any future policy with regards to part time learning in higher education. 
UCU offer the following comments on specific issues which relate to:
Entitlement to new fee grants and tuition fee loans for part time students
The consultation document notes that part-time students will be entitled to a new fee grant that will dependent on the student applying for (and taking up) a tuition fee loan.

UCU welcomes the Welsh Government’s commitment to ending up front fees for part time students, and the introduction of a new loan and grant system which will ensure that part time students are not penalised for choosing to follow a part-time route of study.

Despite this, UCU has concerns over the lack of parity for full-time and part-time students’ access to the new tuition fee grant. The consultation outlines plans for part-time students’ entitlement to a new fee grant on the condition that they take out a tuition fee loan, this is not the same for full-time students. Full-time students are able to access the new tuition fee grant regardless of whether they take out a tuition fee loan.

UCU is concerned that this lack of parity of fee support between full-time and part-time students disadvantages part time students. 

Student loan repayment period

The consultation document outlines plans for part time students to start repaying their loan after their third year of study if their income is above the threshold of £21,000, even if they are still studying.
UCU disagrees with the Welsh Government over the plans for part time students to repay their loan after their third year of study. Whilst we believe that £21,000 is an acceptable repayment threshold, as it is for full time students, we don’t believe that students should be expected to start repaying their student loans after their third year of study.
Many students choose to conduct their studies on a part-time basis for a number of reasons. Some students might choose to study part-time to fit around their family life as a student parent, for which the cost of studying as well as the cost and availability of childcare would be a factor in their decision to study through this format. Repayment of their loan after their third year would result in a deduction in their salary, which would mean less money being made available to them during their time as a student. This would be the same for students deciding to take a break from their studies after their third year, if their income is in excess of £21,000. 
Part time education allows the individual to study in a flexible, bite-sized learning environment, as well as allowing the flexibility in changing skills, and we believe that earlier repayment could be detrimental to this.
UCU believes the Welsh Government’s plans for part-time students to start repaying their loans after their third year of study are unacceptable, and the plans for repayment should be brought in line with those studying full time. UCU believes that for parity with full time students, part-time students should repay their loans upon graduation, if their income is above £21,000.
Fee loans for private institutions
The consultation document outlines Welsh Government plans to provide a fee loan for those studying designated courses at private institutions. 
UCU disagrees that the Welsh Government should be providing fee loans for students studying at private institutions. UCU believes that the public purse should not be funding, albeit through the student, any private institution that is not subject to the same regulations as public institutions. Taking this forward, these private institutions would be receiving public funding and would not be answerable to the Welsh Government policies outlined in “Economic Renewal: a new direction” and “For our future”.
UCU has concerns that these proposals for provision of fee loans for students wishing to study at private institutions could allow the creation of private institutions in Wales through the back door. In England, we have already seen private institutions gain university status, thus providing a private sector higher education system running alongside a public sector university sector. UCU believe that this approach of private institutions can be damaging for higher education, academia and the student in Wales.
UCU believes that if HEFCW are bound to finance any student wishing to follow a part-time course at a private institution, then that institution must be bound by the same regulations as any public institution in Wales including quality assurance processes, maintaining terms and conditions for staff (including national bargaining) and ensuring that any fee cap is no higher than those charged at Welsh public institutions. 

Selected Consultation Questions
Q5. We intend to introduce support arrangements for part-time undergraduates which are similar to those for full-time undergraduates including access to a loan and a fee grant to cover the upfront costs of tuition fees for part-time courses between 25–75 per cent intensity of a full-time course. Will these arrangements encourage applications for part-time study? 
UCU welcomes the Welsh Government’s plans to introduce support arrangements for part-time undergraduates which are similar to those for full-time undergraduates, as well including access to a loan and fee grant to cover the up-front costs for part-time courses between 25-75% intensity of a full-time course. 

Despite this, UCU believes that the Welsh Government needs to ensure that the fee grant should be made available to all part-time students, regardless if they take out a loan or not, to ensure the parity between full-time and part-time undergraduates and that there is no disadvantage to choosing to study part-time. Full-time undergraduates will receive a fee grant regardless of their choice to take out a tuition fee loan; UCU believes this should be the same for part-time undergraduates.
UCU disagrees with the Welsh Government over the plans for part time students to repay their loan after their third year of study. Whilst we believe that £21,000 is an acceptable repayment threshold, as it is for full time students, we don’t believe that students should be expected to start repaying their student loans after their third year of study. 
Part time education allows the individual to study in a flexible, bite-sized learning environment, as well as allowing the flexibility in changing skills, and we believe that earlier repayment could be detrimental to this.
UCU believes the Welsh Government’s plans for part-time students to start repaying their loans after their third year of study are unacceptable, and the plans for repayment should be brought in line with those studying full time. UCU believes that for parity with full time students, part-time students should repay their loans upon graduation, if their income is above £21,000.

Q6. We propose to make a tuition fee loan available for part-time students studying designated courses at private providers. The arrangements proposed for full-time students will provide for a maximum fee loan of £6,000. What do you consider should be the maximum loan available for part-time students? 
UCU disagrees that the Welsh Government should be providing fee loans for students studying at private institutions. UCU believes that the public purse should not be funding, albeit through the student, any private institution that is not applicable to the same regulations as public institutions. 
UCU believes that if HEFCW are required by law to finance any student wishing to follow a part-time course at a private institution, then that institution must be bound by the same regulations as any public institution in Wales including quality assurance processes, maintaining terms and conditions for staff (including national bargaining) and ensuring that any fee cap is no higher than those charged at Welsh public institutions. 
Ends