I declare my interests as in the register, and welcome the Government’s attempts to protect higher education institutions and students. However, I have concerns about the unintended side-effects of these regulations on two issues.
First, there is the process of bids for the 10,000 additional places in excess of the SNC. Who is assessing condition B1 about course design, or condition B4 about qualifications holding value over time, given the radical changes to the economy and teaching methods that may result from the coronavirus? Can my noble friend say whether there is an appeals process for institutions which feel unfairly treated to raise timely concerns? Also, how do the Government assess the impact of using student loan data, which obviously leaves out those who apply late?
This leads me to my second concern. The Independent Higher Education organisation has brought an important issue to my attention today. A one-size-fits-all policy on student numbers may endanger the survival of smaller, specialist providers. In light of my noble friend’s introductory words, with which I agree, saying that we need a range of providers catering for individual needs and to ensure the stability of the sector, I fear that this SI could have a deleterious impact—particularly on students from widening participation categories, who tend to apply late and more often to the smaller higher education establishments.
The effect of introducing the SNC has apparently led larger university partners of smaller specialist colleges to reduce previously agreed numbers of subcontracted places by 20%, so many mature and BAME applicants, who are most likely not to have accepted offers promptly, have had offers withdrawn. Can my noble friend say whether the Government might consider exempting the smallest specialist higher education institutions from these controls: for example, only those with fewer than 1,500 students? They represent under 1% of the higher education sector but that would help stability and wider access.