Provisional SNC by HC121003135446

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									20 January 2012

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                                                                     Northavon House
                                                                     Coldharbour Lane
                                                                     BRISTOL
                                                                     BS16 1QD

                                                                     Telephone 0117 931 <HEPAext>
                                                                     E-mail <HEPA e-mail>
                                                                     www.hefce.ac.uk




Dear <Salutation>

Provisional student number control limit for 2012-13

1.    I am writing to inform you of your institution’s provisional student number control limit
for 2012-13. The limit is provisional because it is subject to appeal and does not yet include
any student places that may be awarded following the invitation to institutions to bid for
numbers from the 'margin' of up to 20,000 places (see HEFCE 2011/301).

2.    As you will be aware, there are a number of important changes to the student number
control process for 2012-13. The Government’s vision is for a more diverse, responsive
higher education system which encourages greater competition and choice for students.
The White Paper ‘Students at the heart of the system’ and the Department for Business,
Innovation and Skills (BIS) technical consultation on a new regulatory framework for higher
education2 set out its intention to free up the control of student numbers to allow a more
dynamic system. For 2012-13, it is doing this in two ways:




1
    ‘Student number controls for 2012-13: invitation to bid for student places’ (HEFCE 2011/30) is
available at: http://www.hefce.ac.uk/pubs/hefce/2011/11_30/.
2
    ‘The White Paper was published on 28 June 2011 and is available at:
http://discuss.bis.gov.uk/hereform/white-paper/. The BIS technical consultation was published on
4 August 2011 and is available at: http://discuss.bis.gov.uk/hereform/technical-consultation/.


Chairman Tim Melville-Ross Chief Executive Sir Alan Langlands FRSE
        a.    Students with entry qualifications equivalent to, or higher than, grades AAB at
        A-level (‘AAB+ equivalent students’) are being excluded from the student number
        control population.

        b.     A ‘margin’ of up to 20,000 places is being created by reducing the ‘core’
        residual student number control population (that is, those remaining after removing
        AAB+ equivalent students). These places are being redistributed only to those
        institutions charging an average annual net tuition fee (after fee waivers) of £7,500 or
        less and meeting other criteria of quality and demand.

3.     We are announcing provisional student number control limits now to help institutions’
planning, although we have not yet had a grant letter from BIS for 2012-13. Failure to issue
this guidance at a critical stage in the 2012-13 admissions cycle would damage the student
interest, risking the possibility of delay and uncertainty for applicants. Cash and student
numbers are constrained. We need to give clarity to institutions about recruitment in
2012-13 to reduce the risk of over-recruitment and consequent pressure on student loans
and support budgets. Excess student support costs would in turn risk further erosion of
funding for key Government priorities like science, technology, engineering and
mathematics (STEM) subjects and widening participation. HEFCE has a clear responsibility
to act in the student interest, to ensure effective stewardship of public money and give the
best guidance it can at this stage about student numbers.

4.     We expect our grant letter will provide further information about the Government’s
overall student number plans for 2012-13 and that it will confirm that the 10,000 additional
entrant places that it made available for 2011-12 are not being repeated for 2012-13. We
believe that it will also ask us to make a further reduction of at least 5,000 places so that the
overall student number control limits we set do not significantly exceed the recruitment level
assumed in the Government’s expenditure plans. The limits have previously involved some
over-allocation, recognising that, as maxima, some under-recruitment against them was to
be expected. However, given recent strong recruitment, coupled with the increased cost of
student support for unplanned numbers, we need to reduce further the overall limits we are
setting for 2012-13. This expected further reduction of 5,000 is reflected in the limits we are
announcing today: if our forthcoming grant letter asks for a different adjustment, we will
issue a revised version of Annex A as soon as we can. The overall implications for
institutions in 2012-13 depend not just on the provisional student number control limits set
out in this letter, but also the places to be awarded from the ‘margin’ in the week
commencing 30 January. The final position will also depend on institutions’ ability to
maintain or increase the numbers of AAB+ equivalent students that they recruit, and the
levels of income they receive through the new tuition fee arrangements.

5.   The policies on the student number control have introduced a greater level of
complexity than in previous years. We consulted in 2011 on our implementation of the
Government’s policies for 2012-13 in HEFCE 2011/203. Our approach to controlling student



3
    ‘Teaching funding and student number controls: consultation on changes to be implemented in
2012-13’ (HEFCE 2011/20) is available at: http://www.hefce.ac.uk/pubs/hefce/2011/11_20/.


Chairman Tim Melville-Ross Chief Executive Sir Alan Langlands FRSE
numbers in 2012-13 reflects responses to this consultation, and is described in HEFCE
2011/30. This letter and its annexes give more detail about the process:

       a.     The letter gives an overview of the main changes to the student number control
       policy in 2012-13. It sets out our approach to recruitment above or below the limit; the
       process for institutions wishing to correct underlying individualised student data for
       2010-11 which affect the student number control calculation; and the date by which
       institutions may appeal for a change to their allocation.

       b.   Annex A sets out the provisional limit that we have set for your institution for
       2012-13. This is contained within a separate Excel workbook which can also be
       downloaded from the HEFCE extranet, from the same location as this letter.

       c.     Annex B defines the student numbers that are included in the limit. This differs
       for some specialist institutions in the performing and creative arts that recruit mainly
       on the basis of audition or portfolio. It also sets out the action we will take if
       institutions exceed their limit in 2012-13 and what action is expected in 2012-13 of
       institutions that over-recruited in earlier years.

       d.    Annex C explains how we calculated your provisional limit and the process and
       timetable for requesting amendments to the provisional limit.

Student number control policy in subsequent years

6.    The arrangements described in this letter and annexes apply only to 2012-13. The
arrangements for setting student number controls, or any alternative to them, for 2013-14
and subsequent years have not yet been decided. We will consult on these as part of the
second stage of our teaching funding consultation. The consultation will also consider
whether or not the student number control mechanism should be extended to cover part-
time students.

7.    We plan to publish this consultation at the end of February 2012, with a deadline for
responses of June 2012. Our Board will consider any changes in the light of the
consultation responses in July 2012. Institutions should assume that there will be no
advantage to be gained in either 2012-13 or in subsequent years from over-recruiting
in 2012-13.

Population included in the student number control for 2012-13

8.     The provisional student number control limit for your institution (given in Annex A)
reflects the change to the student number control described in paragraph 2.a above: that is,
for most institutions it excludes AAB+ equivalent students. It also excludes students
on medical and dental courses that lead to first registration as a doctor or dentist.

9.    Our list of entry grade and qualification combinations considered equivalent to AAB at
A-level or above (provided in paragraph 4.b of Annex B) has been developed solely for the
purpose of operating a student number control. It is not a comprehensive or exhaustive



Chairman Tim Melville-Ross Chief Executive Sir Alan Langlands FRSE
assessment of students’ prior attainment and we therefore consider it too restrictive and
inappropriate to use for other purposes, such as determining the suitability for admission of
individual applicants or eligibility for institutions’ own scholarship, bursary or fee waiver
schemes. In setting the student number control limits for 2012-13, we have ensured that
institutions continue to have flexibility to recruit students with high grade entry qualifications
that are not included in the list of AAB+ equivalences.

10. HEFCE 2011/30 invited specialist institutions in the performing and creative arts that
recruit primarily on the basis of audition or portfolio to make a case if they wished to opt out
of both the AAB+ equivalent and core/margin elements of the student number control. This
invitation was in response to comments received following the consultation in HEFCE
2011/20 that the AAB+ equivalent policy could otherwise distort their admissions processes,
because they do not recruit primarily on the basis of traditional qualifications such as A-
levels. We have considered the responses we received to our invitation and agreed to
exclude a number of such institutions. These institutions are listed in paragraph 3 of Annex
B and their student number control continues to apply as in previous years to all students
starting HEFCE-fundable full-time undergraduate and PGCE study in 2012-13, including
AAB+ equivalent students.

11. As paragraph 2.b explains, the Government has created a ‘margin’ of up to 20,000
places to be redistributed to institutions charging an average annual net tuition fee (after fee
waivers) of £7,500 or less and meeting other criteria relating to quality and demand. We
invited eligible institutions to bid for these places in HEFCE 2010/30, and our Board will
agree the allocation of places at its meeting on 27 January. We will inform individual
institutions of the outcomes of their bids as soon as possible thereafter, in the week
beginning 30 January. The provisional limit in Annex A includes the reduction
necessary to create the margin, but excludes the reallocation of these margin places.
Those institutions that are awarded places from the margin will have these added to their
student number control limit once they have been agreed.

12. We will confirm the student number control limits for your institution in the week
beginning 27 February 2012 to incorporate the outcomes of any appeals, as well as the
inclusion of any places awarded from the margin. The limits will also be shown in the grant
letter that you will receive from us on 19 March 2012.

Over-recruitment against the student number control limit

Over-recruitment in 2012-13

13. We understand that HEFCE’s grant letter from BIS will set out the principles that the
Department will adopt in calculating the rate of grant reductions for institutions for each
student recruited in excess of their 2012-13 limit. These will include:

       avoiding unanticipated pressures on BIS budgets
       removing any financial incentives for institutions to recruit above their permitted
        level
       recognising the different fees charged by institutions



Chairman Tim Melville-Ross Chief Executive Sir Alan Langlands FRSE
       recouping an element to cover the costs of providing maintenance support.

14. BIS will provide further guidance to us on this in due course. In the meantime,
institutions should plan on the basis that (as currently) the rate of grant reduction for
students recruited above the student number control limit for 2012-13 will exceed any tuition
fee income associated with the excess numbers.

15. In addition, paragraph 107 of HEFCE 2011/20 also warned institutions that we may
not count students recruited in excess of the 2012-13 student number control towards our
funding of ‘new-regime’ students in high cost subjects: we intend to apply this to all years of
study relating to the excess numbers recruited.

16. The rate at which grant will be reduced for excess recruitment is intended to provide a
strong incentive for institutions to remain within their limit. However, if we find that,
notwithstanding these measures, institutions exceed their limits significantly or repeatedly,
we may take further action. This may include, but not be limited to: further grant reductions,
exclusion from bidding for places from the student number control margin, or reductions to
their future student number control limits.

Over-recruitment in previous years

17. Where institutions exceeded their student number control limit for 2011-12, and/or
where they exceeded their limit for 2010-11 and did not sufficiently offset that over-
recruitment in 2011-12, they will again be required to offset the over-recruitment if they are
to avoid it leading to a further grant reduction in 2012-13. Offset is achieved by recruiting
below the student number control limit set and the amount of offset required to avoid any
further reduction in 2012-13 arising from over-recruitment in earlier years will be specified in
institutions’ March 2012 grant letters. This timetable allows us to take account, in calculating
any expected offset, of the outcome of any appeals against grant adjustments for over-
recruitment in 2011-12. If institutions fail to offset such past over-recruitment, they will be
subject to a grant reduction of £3,800 (or such other rate as BIS may specify) for each
student place that has not been offset. We are no longer seeking offset in 2012-13 for over-
recruitment that arose in 2009-10.

18. We will monitor whether offset has occurred against the same student population and
limit as applies to the 2012-13 student number control. That is, for most institutions, offset
will be required within the population that excludes AAB+ equivalent students. We will not
accept reductions in the recruitment of AAB+ equivalent students as evidence of offset, as
our assumption will be that any such students will instead have been recruited by another
institution (outside the student number control limit) and will thus continue to be a call on
student support. It is at least theoretically possible that the level of offset required to avoid a
repeat of a grant reduction for over-recruitment in 2011-12 is greater than an institution’s
student number control limit for 2012-13. In this situation, the institution is guaranteed to
have some repeat of its grant reduction in 2012-13, but may have an opportunity to avoid
this recurring in 2013-14 or beyond, subject to recruiting below its student number control
limit in that year. This is reasonable because those excess student numbers represent a




Chairman Tim Melville-Ross Chief Executive Sir Alan Langlands FRSE
continuing call on the student support budget. An example of this is provided below
paragraph 12 of Annex B.

19. It is for institutions to determine their own approach in deciding how much past over-
recruitment they seek to offset by recruiting below their 2012-13 student number control
limit, given the financial implications of different strategies. Institutions may wish to bear in
mind:

             The levels of fee income they may receive for new-regime students in 2012-13

            The rate at which grant adjustments apply relating to over-recruitment that
       occurred prior to 2012-13 (as explained in paragraph 17)

             The impact of any offset in allowing institutions to maintain viable cohort sizes

            The impact of any offset on all-year student numbers (and thus fee income)
       both in 2012-13 and later years.

Recruitment of full-time undergraduate and PGCE students not covered by the student
number control

20. The exclusion from the student number control of AAB+ equivalent students means
institutions (other than the named specialist institutions in the performing and creative arts)
are now able to compete freely for such students and to increase their number as they wish
and are able. This applies only to those students that meet the definition of AAB+ equivalent
given in Annex B paragraph 4.b and who are not subject to other intake targets.

21. Students on medical and dental courses leading to first registration as a doctor or
dentist are excluded from the student number control, whether or not their entry
qualifications are equivalent to AAB+ at A-level. This exclusion is on the basis that their
numbers are already controlled through the setting of intake targets. David Noyce wrote to
institutions with medical/dental schools on 13 April 2011 reminding institutions of the
importance of adhering to their intake targets and warning of possible further action if they
did not. Paragraph 107 of HEFCE 2011/20 also warned institutions that we may not count
students recruited in excess of medical and dental intake targets towards our funding of
‘new-regime’ students in high cost subjects: this would apply to all years of study relating to
the excess numbers recruited. Institutions should therefore ensure that they do not
exceed their medical and dental intake targets for 2012-13 (irrespective of students’
entry qualifications). We may take further action against institutions that continue to exceed
their targets and we will be writing separately to those institutions that we consider have
significantly over-recruited in 2011-12.

22. Students on initial teacher training courses leading to qualified teacher status
(ITT(QTS) courses) are also excluded from the student number control because they are
subject to separate intake controls currently set by the Training and Development Agency
for Schools (TDA) and in future by the new Teaching Agency (TA). However, they remain a
call on the student support budget – increasingly so under the new fee regime being



Chairman Tim Melville-Ross Chief Executive Sir Alan Langlands FRSE
introduced from 1 September 2012. The TDA has informed providers of their allocations for
2012-13 and has been clear in its correspondence that institutions must adhere to these
allocations. In particular, Tom Glover’s letter to providers of 17 November 2011 stated:

        ‘The TDA/TA has been remitted to control the total supply of teachers to schools. It
        will continue to manage this process through the use of allocated places and, if
        appropriate, further sanctions. We will consult on the technical changes required for
        this regulation shortly. However, to allow providers to prepare in their approach to
        recruitment it must be made clear that any allocations to providers must not be
        exceeded. These allocations are for all trainees, not just those that receive
        bursaries. Any provider uncertain on this issue should contact the TDA to discuss.’

23. There remain some student populations which are a call on student support, but
which are not currently covered by the student number control. These include AAB+
equivalent students, those on first registrable medicine and dentistry and ITT(QTS) courses,
part-time students and some students funded by other public bodies, such as those on
NHS-funded nursing and midwifery courses who are not in receipt of an NHS bursary. If
overall increases in these populations lead to unplanned student support costs, then further
action may be taken, including adjusting future student number control limits for individual
institutions and/or changing the population that it covers.

Implications of recruiting below the 2012-13 student number control limit

24. We will not adjust grant for institutions merely for recruiting below their student
number control limit for 2012-13 (other than where shortfalls are insufficient to offset past
over-recruitment as explained above). However, where institutions recruit significantly below
their student number control limit in 2012-13, this may lead to a reduction to their baseline
control limit for future years. In this context, significant means by more than 5 per cent or 25
students, whichever is the larger, after adjusting the limit to take account of any offset
required as a result of past over-recruitment.

25. We excluded non-AAB+ equivalent students in strategically important and vulnerable
subjects (SIVS) from the reductions necessary to create the 20,000 margin on the condition
that their numbers are maintained. We reserve the right to take further action in individual
cases where institutions show significant and repeated shortfalls in non-AAB+ equivalent
students in SIVS. In such exceptional circumstances, we may look to redistribute places to
institutions that are better able to fill them.

26. In setting student number control limits for 2012-13, we have ensured that institutions
have retained at least 20 per cent of their limit for 2011-12, after removal of medical and
dental students, the temporary uplift of 2 per cent that was provided only for that year and
the further reduction of at least 5,000 places to the overall 2012-13 limits for the sector
which we expect to be confirmed in our grant letter from BIS. We have not yet made
decisions about continuation of this policy into 2013-14. This will depend in part on any
other developments of the student number control policy from that year, following
consultation.




Chairman Tim Melville-Ross Chief Executive Sir Alan Langlands FRSE
Responses required and next steps

27. There is no need to reply to this letter unless (i) you wish to let us know about
corrections to underlying individualised student data for 2010-11; and/or (ii) you wish to
appeal for a change to your provisional limit so that it takes account of particular institutional
circumstances. There will also be an opportunity to appeal for a change to the award of
places from the margin, when these have been confirmed.

28. Errors in institutions’ 2010-11 Higher Education Statistics Agency (HESA) or
Individualised Learner Record (ILR) data may affect the provisional student number control
limit that we have calculated. Specifically, this relates to:

       a.     The adjustments we have made for higher education institutions to exclude
       AAB+ equivalent students and those on first registrable medical and dental courses
       from the control. We do not expect responses from further education colleges relating
       to the identification of AAB+ equivalent students, because their adjustments are
       based on their 2011-12 Higher Education in Further Education Students (HEIFES11)
       survey.

       b.   Our identification for both higher and further education institutions of the
       proportions of non-AAB+ equivalent students who are studying in SIVS.

29. Institutions wishing to correct 2010-11 HESA or ILR data are required to submit an
action plan by 17 February 2012 and to have signed off their data amendments by
2 March 2012.

30. If you wish to appeal to us to take account of particular institutional circumstances,
any appeal must be submitted by Wednesday 8 February 2012 to your HEFCE Regional
Consultant, <RCname> (direct line: 0117 931 <RCExt>; e-mail: <RCmail>). Paragraphs 46
to 53 of Annex C provide guidance for institutions wishing to appeal for a change to their
limit. If institutions believe their limit has been set at a level significantly above what they
expect to need and wish it to be reduced, they may similarly contact us to request this.

31. Places to be awarded following bids to the student number control margin invited in
HEFCE 2011/30 have not yet been decided or included in the provisional limits announced
in Annex A. They will be announced during the week beginning 30 January. If institutions
then wish to appeal for a change to the margin places awarded, the deadline for submission
will be the same as for other appeals – that is, by Wednesday 8 February 2012 and sent
as before to the HEFCE Regional Consultant. The letter announcing margin allocations will
provide more detail about the criteria for such appeals. This timescale is necessary to
ensure we are able to confirm student number control limits later that month.

32. We aim to confirm the student number control limits in the light of appeals, and
incorporating the outcomes of the margin bids, during the week beginning 27 February
2012. They will also be shown in the individual grant tables that institutions will receive on
19 March 2012. Our grant announcement will remain under embargo until 0001 on
Thursday 22 March 2012. Any changes to limits arising from corrections to HESA or ILR



Chairman Tim Melville-Ross Chief Executive Sir Alan Langlands FRSE
data for 2010-11 are likely to be confirmed at a later date: the precise timing will depend on
our discussions with institutions about their data.

33. Any questions about this letter should be sent to your HEFCE Higher Education
Policy Adviser, <HEPAname> (direct line: 0117 931 <HEPAExt>; e-mail: <HEPAmail>).

Yours sincerely




Caroline Charlton
Funding Round Manager




Chairman Tim Melville-Ross Chief Executive Sir Alan Langlands FRSE
Provisional student number control limit for 2012-13: Annex B to letter of 20 January 2012




Annex B: The student number control population and monitoring against it

Population covered by the student number control for 2012-13

1.    Except for the institutions identified in paragraph 3 (for whom the definition in
paragraph 2 applies), years of instance or programme of study meeting the following criteria
count towards the student number control that we are setting for 2012-13:

       a.     Either:

              i.      They are for HEFCE-fundable or employer co-funded, full-time,
              undergraduate students active in the academic year 1 August 2012 to 31 July
              2013, but excluding those on medicine and dentistry courses who are aiming
              for a first registrable qualification as a doctor or dentist.

              and

              Their qualifications and grades on entry are not AAB+ equivalent.

              and

              The students have not been HEFCE-fundable or employer co-funded full-time
              undergraduate students in either of the preceding two academic years (that is,
              between 1 August 2010 and 31 July 2012) as students of the same institution.
              These categories include students who do not complete their year of
              instance/programme of study.

              Or:

              ii.    They are for HEFCE-fundable or employer co-funded full-time students
              aiming for a PGCE (whether a Postgraduate or Professional Graduate
              Certificate in Education) commencing a programme of study in the academic
              year 1 August 2012 to 31 July 2013.

       b.    The students have not withdrawn from their programme of study within two
       weeks of starting: that is, they have undertaken sufficient activity to be required to be
       included in the Higher Education Statistics Agency (HESA) student record or Data
       Service Individualised Learner Record (ILR).

2.     Following responses to ‘Student number controls for 2012-13: invitation to bid for
student places’, HEFCE 2011/30, specialist institutions in the performing and creative arts
listed in paragraph 3 have been excluded from both the AAB+ equivalent and core/margin
elements of the student number control. These institutions were invited, and have chosen,
to opt out of these elements of the control, on the basis that the AAB+ equivalent policy
could otherwise distort their admissions processes, because they recruit primarily using
auditions or portfolios rather than traditional qualifications such as A Levels. For them, years
of instance or programme of study meeting the criteria in paragraph 1 are counted towards


                                                                                                   1
Provisional student number control limit for 2012-13: Annex B to letter of 20 January 2012




the student number control we are setting for 2012-13, subject to a revision to the wording
of paragraph 1.a.i to read:

              i.    They are for HEFCE-fundable or employer co-funded, full-time,
              undergraduate students active in the academic year 1 August 2012 to 31 July
              2013.

              and

              The students have not been HEFCE-fundable or employer co-funded full-time
              undergraduate students in either of the preceding two academic years (that is,
              between 1 August 2010 and 31 July 2012) as students of the same institution.
              These categories include students who do not complete their year of
              instance/programme of study.

3.    The specialist institutions in the performing and creative arts to which paragraph 2
applies are:

      Higher education institutions
      Arts University College at Bournemouth
      Central School of Speech and Drama
      University for the Creative Arts
      Conservatoire for Dance and Drama
      University College Falmouth
      Guildhall School of Music and Drama
      Leeds College of Art
      Liverpool Institute for Performing Arts
      University of the Arts London
      Norwich University College of the Arts
      Ravensbourne
      Rose Bruford College
      Royal Academy of Music
      Royal College of Music
      Royal Northern College of Music
      Trinity Laban Conservatoire

      Further education colleges
      Hereford College of Arts
      Plymouth College of Art

4.     Terms used in the definition of the student number control are:

       a.     Employer co-funded:

              i.    This applies to years of instance/programme of study that are HEFCE
              non-fundable on the basis that they are to count towards the delivery of HEFCE

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Provisional student number control limit for 2012-13: Annex B to letter of 20 January 2012




                allocations of student numbers co-funded with employers (see paragraph 9b of
                Annex K of HESES11 and HEIFES11). This may include years of
                instance/programme of study where students are aiming for an ELQ and who,
                were they not co-funded, would not be exempt from the ELQ policy as defined
                in HESES/HEIFES Annex K.

                ii.    Home and EU ‘new-regime’ students in 2012-13 cannot be recorded as
                employer co-funded, but may be either HEFCE-fundable or non-fundable
                depending on other criteria (see HESES11 Annex D paragraph 41/HEIFES11
                Annex D paragraph 39). As the student number control applies to students
                starting study at the institution in the 2012-13 academic year and most of these
                will meet the definition of new-regime in HESES11/HEIFES11 Annex Q, we do
                not expect many employer co-funded students to be included in the student
                number control population. There may, however, be a small number, for
                example, as a result of transfers between institutions.

       b.    AAB+ equivalent: The following grade and qualification combinations are
       considered equivalent to AAB at A-level or higher, and students holding them are not
       included in the 2012-13 student number control population:

              Best three A-levels (including VCE advanced) or best three Scottish Advanced
                Highers, where grades are either:
           —    A*, A*, A*
           —    A*, A*, A
           —    A*, A, A
           —    A*, A*, B
           —    A, A, A
           —    A*, A, B
           —    A*, A*, C
           —    A, A, B
           —    A*, A*, D
           —    A*, A, C
           —    A*, B, B
           —    A*, A* and an A at AS-level.
              A BTEC National with a grade of:
           —    Distinction*, Distinction*, Distinction*
           —    Distinction*, Distinction*, Distinction
           —    Distinction*, Distinction, Distinction
           —    Distinction, Distinction, Distinction.
              Grade A from a CACHE Level 3 diploma in Child Care and Education.
              Grade D1 from an OCR National Extended Diploma.
              A distinction from a NPTC Level 3 Land Based Extended Diploma.
              Grade A* from a Progression Diploma.
              Best five Scottish Highers, grades are either:
           —    A, A, A, A, A
           —    A, A, A, A, B
           —    A, A, A, B, B


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Provisional student number control limit for 2012-13: Annex B to letter of 20 January 2012




         —  A, A, A, A, C
         —  A, B, B, B, B
         —  A, A, B, B, C
         —  A, A, B, B, B
         —  A, A, A, A, D
         —  A, A, A, B, C
         —  A, A, A, C, C
         —  A, A, A, B, D.
         International Baccalaureate with 35 points or more.
         Best four Irish Leaving Certificates, grades are either:
         — A1, A1, A1, A1
         — A1, A1, A1, B1
         — A1, A1, A1, A2.
         A postgraduate research degree.
         A postgraduate taught degree.
         A first degree.

       c.     Students who have not been HEFCE-fundable or employer co-funded full-
       time undergraduates in the two preceding academic years: students who, during
       each academic year 2010-11 and 2011-12, have not undertaken HEFCE-fundable or
       employer co-funded full-time undergraduate study; or if they have, withdrew (on each
       occasion) within two weeks of starting the programme of study; or were otherwise
       ‘dormant’ during that period. In this context, full-time relates to study that, had it been
       finished, would have been full-time.

       d.    The same institution: This refers to the ‘registering’ institution responsible for
       reporting the student in the HESA student record or Data Service ILR. Where
       teaching has been franchised out, the associated (year of) instance/programme of
       study is attributable to the franchiser, not the franchisee.

5.    Guidance on when years of instance/programme of study count towards the student
number control limit in 2011-12 was provided in Annex H of HESES11 and HEIFES11.
However, this did not reflect the change to the student number control population being
introduced from 2012-13 that excludes AAB+ equivalent students and those on medical and
dental courses leading to first registration as a doctor or dentist.

Monitoring compliance with the student number control for 2012-13 and the
action we may take if institutions exceed it

6.     The student number control represents a maximum, not a minimum, student number
for institutions.

7.     We will monitor each institution’s compliance with the student number control limit
that we have specified for them. Where we find that an institution has exceeded its limit, this
will result in a reduction to grant, which may be applied in the 2012-13 and/or subsequent
academic years. We cannot yet specify the rate per excess student at which this grant
reduction will apply. However, we understand that HEFCE’s forthcoming grant letter from

                                                                                                  4
Provisional student number control limit for 2012-13: Annex B to letter of 20 January 2012




BIS will set out the principles that the Department will adopt in calculating the rate of grant
reductions for institutions for each student recruited in excess of their 2012-13 limit. These
will include:

        avoiding unanticipated pressures on BIS budgets
        removing any financial incentives for institutions to recruit above their permitted
         level
        recognising the different fees charged by institutions
        recouping an element to cover the costs of providing maintenance support.

8.     BIS will provide further guidance to us on this in due course. In the meantime,
institutions should plan on the basis that (as currently) the rate of grant reduction for
students recruited above the student number control limit for 2012-13 will exceed any tuition
fee income associated with the excess numbers. The reduction may be repeated in
subsequent years to the extent that we consider the excess students recruited in 2012-13
continue to contribute to excess student support costs at the institution. We will give
institutions an opportunity to appeal for mitigation before finalising any such grant
adjustment.

9.    No margin above the limit specified for 2012-13 will apply before we seek to make
grant reductions.

10. Initially we will monitor compliance with the student number control through the
HESES and HEIFES surveys. A new Table 6 was introduced to these surveys in 2010 for
this purpose. We will also undertake further monitoring using the end of year HESA and ILR
data for 2012-13. This may result in an additional grant adjustment or changes to any grant
adjustments we have previously confirmed or changes to any student number control limit
already notified for later years.

Requirements on institutions that over-recruited in previous years

11. In addition, where institutions exceeded their student number control limit for 2011-12,
and/or where they exceeded their limit for 2010-11 and did not sufficiently offset that over-
recruitment in 2011-12, they will again be required to offset the over-recruitment if they are
to avoid it leading to a further grant reduction in 2012-13. Offset is achieved by recruiting
below the student number control limit set. The amount of offset required to avoid any
further reduction in 2012-13 arising from over-recruitment in earlier years will be specified in
institutions’ March 2012 recurrent grant letters. This timetable allows us to take account, in
calculating any expected offset, of the outcome of any appeals against grant adjustments
for over-recruitment in 2011-12. If institutions fail to offset such past over-recruitment, they
will be subject to a grant reduction of £3,800 (or such other rate as BIS may specify) for
each student place that has not been offset. We are no longer seeking offset in 2012-13 for
over-recruitment that arose in 2009-10.

12. We will monitor whether offset has occurred against the same student population and
limit as applies to the 2012-13 student number control. That is, for most institutions, offset
will be required within the population that excludes AAB+ equivalent and medical and dental

                                                                                                  5
Provisional student number control limit for 2012-13: Annex B to letter of 20 January 2012




students. We will not accept reductions in the recruitment of AAB+ equivalent students as
evidence of offset, as our assumption will be that any such students will instead have been
recruited by another institution (outside the student number control limit) and will thus
continue to be a call on student support. It is at least theoretically possible that the level of
offset required to avoid a repeat of a grant reduction for over-recruitment in 2011-12 is
greater than an institution’s student number control limit for 2012-13. In this situation, the
institution is guaranteed to have some repeat of its grant reduction in 2012-13, but may
have an opportunity to avoid this recurring in 2013-14 or beyond, subject to recruiting below
its student number control limit in that later year. This is reasonable because those excess
student numbers represent a continuing call on the student support budget.


         Example

         An institution exceeds its student number control limit for 2011-12 by 200 students.
         We expect 90 per cent of these students will continue their studies into 2012-13, so
         we expect offset of 180 in that year. As a result of the AAB+ policy and other
         adjustments, the institution’s student number control for 2012-13 is set at 150. In
         this situation, if the institution recruits no students that meet the student number
         control definition in 2012-13, it will have offset only 150 of the 180 places required
         as a result of the over-recruitment in 2011-12. It will therefore have a further grant
         reduction in 2012-13 relating to the balance of 30 places that were not (and could
         not be) offset. This is reasonable because those excess student numbers represent
         a continuing call on the student support budget. To the extent that any of the excess
         2011-12 student numbers are expected to continue their studies into 2013-14, there
         may then be a further opportunity to offset any remaining places that were not offset
         in 2012-13.




                                                                                                6
Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




Annex C: Calculation of 2012-13 student number control limits and the
process and timetable for seeking changes

Calculation of the provisional student number control limits for 2012-13

1.    Annex A shows the derivation of the provisional student number control limit for
2012-13. The row headings in the table are described below. Italics in the descriptions are
used to refer to a figure from another row in the table.

2.    We will separately provide institutions, by 25 January, with further details of how
2010-11 Higher Education Statistics Agency (HESA) and Individualised Learner Record
(ILR) data were used to inform these calculations, as well as the process for submitting
amendments to HESA or ILR data. This will include the full specification of the algorithms as
well as a data file showing how each student (from their HESA or ILR data) contributed
towards the adjustments and, if they did not contribute, the reason why.

3.     Specialist institutions in the performing and creative arts that recruit mainly on the
basis of audition or portfolio were invited to make a case for being excluded from the AAB+
and core/margin policies. Following responses from those institutions, we have agreed that
those policies should not apply to the institutions listed in Annex B paragraph 3. In the
descriptions of the calculation of the provisional 2012-13 student number control limit,
paragraphs 9 to 11 and 13 to 34 are not relevant to them, because they are concerned with
adjustments relating to the AAB+ equivalent student population and core/margin policies –
the figures they describe will be shown as zero in the tables for those institutions.

2011-12 Student number control limit
4.   This is taken from the final issue of the 2011-12 recurrent grant Table B.

Change in FT UG students as a result of transfers of provision between institutions for
2011-12
5.    This is a reduction for some institutions that were subject to a transfer-in of FT UG
provision in 2011-12. The reduction reflects the difference between the all-year numbers
added in 2011-12 and the level of entrants that are to be maintained from 2012-13, as
agreed with the institutions concerned.

Removal of the 2 per cent uplift given in 2011-12
6.     Caroline Charlton’s letter of 31 January 2011, which announced the provisional
student number control limit for that year, explained that we were providing an uplift of 2 per
cent to the limits for institutions so that, at the sector level, there was no reduction required
in the number of entrant places for 2011-12. We expect the Department for Business,
Innovation and Skills (BIS) to confirm in its forthcoming grant letter to us that the 10,000
additional places first awarded through the University Modernisation Fund for 2010-11 and
then redistributed through last year’s 2 per cent uplift to the student number control are not
being repeated for 2012-13. We are therefore withdrawing the addition to the student
number control limit that institutions accepted last year as a result of this 2 per cent uplift.




                                                                                                1
Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




Change as a result of data audit or reconciliation exercise
7.   This is an adjustment to individual institutions’ 2011-12 student number control limit
agreed after the final issue of 2011-12 grant tables that arises from recent Higher Education
Students Early Statistics (HESES) or Higher Education in Further Education: Students
(HEIFES) data audits or reconciliation exercises, as separately notified.

Pro rata reduction to limits for 2012-13
8.     We expect that in its forthcoming grant letter BIS will ask us to make a further
reduction of at least 5,000 places so that the overall student number control limits we set do
not significantly exceed the recruitment level assumed in the Government’s expenditure
plans. The limits have previously involved some over-allocation, recognising that, as
maxima, some under-recruitment against them was to be expected. However, given recent
strong recruitment, coupled with the increased cost of student support for unplanned
numbers, we need to reduce further the overall limits we are setting for 2012-13. We are
therefore making a reduction of 5,000 pro rata to the limits for all institutions. This amounts
to a reduction of about 1.4 per cent. If our forthcoming grant letter asks for a different
adjustment, we will issue a revised version of Annex A as soon as we can.

Removal of medicine and dentistry students
9.    ‘Teaching funding and student number controls: Consultation on changes to be
implemented in 2012-13’, HEFCE 2011/20 proposed that full-time undergraduates on
programmes of study that lead to a first registrable medical or dental qualification for
doctors or dentists should be excluded from the student number control, because they are
already separately controlled. This has now been confirmed following that consultation. The
numbers deducted are the number of Home and EU full-time medical or dental
undergraduates that counted against the 2010-11 student number control according to
2010-11 HESA data.

Removal of HEFCE-fundable PGCE students
10. HEFCE-fundable PGCEs are still covered by the student number control for 2012-13.
We deduct them here so that they are not subject to the reductions that arise from
implementation of the AAB+ policy. The PGCE numbers are restored later in the calculation
(see paragraph 23). The PGCE numbers are taken from HESES11/HEIFES11 Table 6.

11. The exclusion from the limit of AAB+ equivalent students applies only to full-time
undergraduates, not to those on PGCE courses. This is because we would expect all
students aiming for a PGCE to already have an honours degree; honours degrees are
included in the list of AAB+ equivalent qualifications, so if the AAB+ policy applied to PGCE
students, they would all be excluded from the control. This would leave an entire area of
provision uncontrolled with a large population of graduates potentially eligible to enrol.

2012-13 Baseline (before pro rata reduction for estimated growth in the AAB+ equivalent
population)
12. This is the sum of the previous six rows.




                                                                                              2
Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




Pro rata reduction for estimated growth in the AAB+ equivalent population
13. This is the figure from the previous row multiplied by approximately minus 1.2 per
cent. At the sector level, this deducts 4,000 places to allow for increases in the AAB+
equivalent population.

2012-13 Baseline
14. This is the sum of the previous two rows.

Proportion of students who are AAB+ equivalent
(Paragraphs 15 to 19 apply to higher education institutions; paragraph 20 applies to further
education colleges)

15. For higher education institutions, the entry qualification and grade information
reported on the HESA student record is sufficient to allow us to determine for most students
whether or not they fall within the AAB+ equivalent population. There has been a significant
improvement in the recording by institutions of entry qualifications on the 2010-11 HESA
record compared to earlier years, which has helped us to better identify whether or not
students come within the AAB+ equivalent population. However, there remain a number
where the HESA data on its own is insufficient to assign students in this way. These
unassigned students fall into two main groups: those where their entry qualifications are not
known; and those known to have entered with particular qualifications, including A-levels,
but where their grades are unknown. This latter group will include students whose highest
qualification on entry is a higher education qualification below first degree level, but whose
A-level grades are not recorded.

16. In order to gain greater certainty about whether or not students have AAB+ equivalent
entry qualifications, we have linked students on the 2010-11 HESA record to two other data
sources: the National Pupil Database (NPD) and the ILR to identify entry qualifications for
those that were not identified as AAB+ equivalent based on the HESA data. The NPD and
ILR provide information on qualifications achieved in English schools and further education
colleges and we have linked to these records going back to 2003-04. We have received
agreement from the Department for Education in relation to the NPD and the Skills Funding
Agency in relation to the ILR for us to use these records for linking to inform our calculation
of student number control limits.

17. Our use of linking to other data sources to inform allocations to individual institutions
is new. While we will be able to summarise for institutions what we have found through
linking, in terms of total numbers in particular categories, we will not be able to share which
specific students we have identified through linking, because of data protection.
Nevertheless we believe our approach enables us to identify AAB+ equivalent students
much more accurately than would otherwise be the case and therefore helps to produce a
fairer outcome for institutions and is entirely reasonable and justified for the intended
purposes. This view is supported by the legal advice we have taken.




                                                                                                  3
Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




18. Our linking is based on first name(s), surname, date of birth and (where available)
home postcode and prior educational establishment. Where we have identified a student as
AAB+ equivalent through linking, we have manually checked (for each individual case) that
these links are appropriate and not merely the erroneous effect of some computer
algorithm. We have removed links in a very small number of cases where we consider there
is any doubt that the link was appropriate – for example, if there is a possibility that our
linking has picked up twins, or merely coincidences of common names. We therefore have
very high confidence that our identification of students as AAB+ equivalent through linking is
extremely accurate – any error rate will be a very small fraction of 1 per cent. The
identification through linking of students as being not AAB+ equivalent will, of course, work
in institutions’ favour, as these are numbers that will not be removed from their student
number control limits.

19. We have therefore taken the following approach to identifying AAB+ equivalent
students at higher education institutions:

       a.     We identified some 327,000 students in the student number control population
       reported on higher education institutions’ 2010-11 HESA returns. Of these the
       following are not considered further in determining the AAB+ equivalent populations:

              i.     Some 7,000 undergraduates on medicine and dentistry courses – these
              are being removed from the student number control from 2012-13 irrespective
              of their entry qualifications, because they are subject to separate intake targets.

              ii.      Some 1,000 students on (HEFCE-fundable) PGCE courses. These are
              still in the control in 2012-13, but the AAB policy does not apply to them, as
              explained in paragraphs 10 and 11.

       b.     Of the remaining 319,000 students, the HESA data indicated that:

              i.      Some 65,000 are AAB+ equivalent students (of whom 3,000 already have
              a first degree).

              ii.   Some 216,000 are not AAB+ equivalent students. Within this total, we
              have included:

                     1)     As an initial default assumption before we revise in light of data
                     linking, all England-domiciled students aged 24 or under, except where
                     the HESA data indicates that they do have AAB+ equivalent
                     qualifications. We have done this because we are confident that if such
                     students had AAB+ equivalent entry qualifications, we would have
                     identified them through our data linking. We do not have equivalent
                     information for UK students domiciled in Scotland, Wales or Northern



                                                                                                 4
Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




                     Ireland, so we estimate how many of them are likely to be AAB+
                     equivalent according to the method described below.

                     2)     All (non-UK) EU-domiciled students that do not have either A-levels
                     or UK or International Baccalaureate entry qualifications. We have done
                     this because they do not have relevant qualification types within our
                     group of AAB+ equivalences.

              iii.  Some 23,000 cannot be assigned from the HESA data or our initial
              default assumptions to either category.

       c.    We have then used data links going back to the 2003-04 NPD and the 2003-04
       ILR to identify entry qualifications for those that were not initially identified as AAB+
       equivalent based on the HESA data. This has allowed us to identify about 7,000
       students as AAB+ equivalent who were not identified as such from the HESA data
       alone. Most of these relate to English students under 25 who we assigned initially to
       non-AAB+ equivalent because of our default assumption. In addition, we have
       concluded from our linking that a further 1,000 students who were previously treated
       as unassigned are in fact not AAB+ equivalent students.

       d.     This approach has left approximately 22,000 students unassigned to either the
       AAB+ equivalent or the not AAB+ equivalent populations even after linking. For these,
       we have had to make assumptions about what proportions should fall into each
       category. This has been calculated by categorising students into combinations of age
       and entry qualification type (for UK students) or just entry qualification type (for EU
       students) and making assumptions based on the characteristics of similar students
       within the known populations at institutions with similar profiles of AAB+ equivalent
       students. So, for example, we will make one assumption for an 18-year-old with
       A-levels going to a highly selective institution, and another assumption about a 20-
       year-old with a BTEC National award going to a “recruiting” institution. We pool each
       institution with up to 10 others using a ranking based on the proportion of non-
       graduate AAB+ equivalent students in the known populations (based on both HESA
       and data linking): each is pooled with the five institutions above and five below in the
       ranking, though institutions at the top and bottom of the ranking will therefore be
       pooled with fewer others. We have used four age groups (up to 18, 19, 20, and 21 or
       over) and nine qualification groups:

              i.     First degree and higher.
              ii.    Other higher education.
              iii.   A-level and equivalent.
              iv.    Baccalaureate.
              v.     Level 3 award or diploma.
              vi.    Level 3 certificate.
              vii.   Other qualification at level 3.


                                                                                               5
Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




              viii.   Access course.
              ix.     Below level 3.

        e.    The outcome of this approach is that a further 1,000 students of the 22,000 are
        assumed to be AAB+ equivalent. We think this is a reasonable estimate and overall a
        much smaller proportion than applies in the whole population, reflecting the fact that
        these students have a different age and entry profile.

20. For further education colleges, this proportion is derived from their HEIFES11 Table 6
data, as:

        Sum of ‘Actual UG in AAB+ equivalent population’ plus ‘Estimated UG in AAB+
         equivalent population’, for both HEFCE-fundable and employer co-funded students
        Divided by the total on Table 6, excluding PGCE students.

Removal of AAB+ equivalent students from the baseline for 2012-13
21. This is the Proportion of students who are AAB+ equivalent multiplied by 2012-13
Baseline, expressed as a negative number.

2012-13 Baseline less AAB+ equivalent students
22. This is the sum of Removal of AAB+ equivalent students from the baseline for
2012-13 and 2012-13 Baseline.

Re-addition of HEFCE-fundable PGCE students
23. This restores the HEFCE-fundable PGCE numbers previously deducted (see
paragraphs 10 and 11).

2012-13 Core student number control
24. This is the sum of the previous two rows and represents the total before adjustments
are made to create and redistribute the margin places.

Proportion of non-AAB+ equivalent students assumed to be in SIVS
25. ‘Student number controls for 2012-13: invitation to bid for student places’, HEFCE
2011/30, explained that, for 2012-13, we would exclude numbers associated with currently
identified strategically important and vulnerable subjects (SIVS) from the calculation to
create the margin. This is on condition that institutions maintain the level of non-AAB+
equivalent entrants to these subjects. We have therefore identified the proportions of non-
AAB+ equivalent students in the student number control population using 2010-11 HESA
data for higher education institutions and 2010-11 ILR data for further education colleges.
The methodologies for each are as follows:

26. For higher education institutions, we remove medical and dental students, AAB+
equivalent students and the number of unassigned students assumed to be AAB+
equivalent from the number of students counting against the 2010-11 student number
control limit. From the resulting non-AAB+ equivalent students (including HEFCE-fundable
PGCEs) we identify those students that are studying for more than 50% of their course aim
in SIVS. We identify SIVS using the list of Joint Academic Coding System (JACS) codes

                                                                                              6
Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




given in question 7 of ‘Teaching funding and student number controls consultation:
frequently asked questions’ (see: www.hefce.ac.uk/learning/funding/201213/faq.htm#q7).

27. We calculate the Proportion of non-AAB+ equivalent students assumed to be in SIVS
by dividing the number of non-AAB+ equivalent students that are studying for more than
50% in SIVS (including HEFCE-fundable PGCEs) by the number of non-AAB+ equivalent
students (including HEFCE-fundable PGCEs).

28. For further education colleges, we identify the number of students counting against
the 2010-11 student number control limit. Within this group we identify those students that
are studying for more than 50% of their learning aim in SIVS. We identify SIVS using the list
of Learndirect codes given in Annex B of ' Support for moving full-time undergraduate
numbers into strategically important and vulnerable subjects (SIVS) in 2010-11' (HEFCE
Circular letter 06/2010).

29. We calculate the Proportion of non-AAB+ equivalent students assumed to be in SIVS
by dividing the number of students that are studying for more than 50% in SIVS by the
number of students counting against the 2010-11 student number control limit.

Removal of non-AAB+ equivalent students assumed to be in SIVS
30. This is the Proportion of non-AAB+ equivalent students assumed to be in SIVS
multiplied by 2012-13 Core student number control, expressed as a negative number.

Disregarding of the first 50 students
31. This is minus 50 for every institution. HEFCE 2011/30 explained that no institution
would be automatically exempt from the calculation to create the margin, but that in
calculating it we would disregard the first 50 places in the population to which the
calculation applies. This avoids reductions for those with small numbers.

Adjusted 2012-13 core student number control
32. This is the population from which the cut to create the margin is taken. It is the higher
of 0 and the sum of 2012-13 Core student number control, Removal of non-AAB+
equivalent students assumed to be in SIVS and Disregarding of the first 50 students.

Pro rata reduction to create the margin
33. This is the Adjusted 2012-13 core student number control multiplied by approximately
minus 9.3 per cent. At the sector level, this deducts 20,000 places to create the margin.

Award of places through the margin
34. This is still to be confirmed for all institutions. These numbers will be announced in
the week beginning 30 January 2012.

Expected change in FT UG students as a result of transfers of provision between
institutions for 2012-13
35. These numbers are not yet confirmed, but will be incorporated subsequently. They
will reflect the change in FT UG numbers meeting the student number control population



                                                                                                7
Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




definition expected as a result of new transfers of provision requested by institutions for
2012-13.

Change as a result of appeals
36. This is currently zero for all institutions, but in subsequent issues of this table this will
show the outcomes of any appeals against the provisional student number control limit that
are submitted in response to this letter.

Provisional 2012-13 student number control limit
37. This is the higher of:

        2012-13 Core student number control, plus
        Pro rata reduction to create the margin, plus
        Award of places through the margin (still to be confirmed), plus
        Expected change in FT UG students as a result of transfers of provision between
         institutions for 2012-13 (still to be confirmed) plus
        Changes as a result of appeals (still to be confirmed).

    Or 20 per cent of the sum of:

        2011-12 Student number control limit, plus
        Change in FT UG students as a result of transfers of provision between institutions
         for 2011-12, plus
        Removal of the 2 per cent uplift given in 2011-12, plus
        Change as a result of data audit or reconciliation exercise, plus
        Pro rata reduction to limits for 2012-13, plus
        Removal of medicine and dentistry students.

38. This calculation implements the decision announced in HEFCE 2011/30 that
institutions should retain a student number control limit equal to at least 20 per cent of their
limit for 2011-12, after removal of the temporary uplift of 2 per cent that was provided only
for that year and the further reduction of at least 5,000 places to the overall 2012-13 limits
for the sector that we expect in the forthcoming grant letter from BIS. Medical and dental
students are also removed in this calculation, because they are subject to separate controls.

Process and timetable for seeking changes to the student number control limit
for 2012-13

39. We will consider requests from institutions for changes to their provisional limit in two
particular circumstances:

        a.    Where they wish to correct underlying individualised student data for 2010-11.

        b.   Where they wish to appeal for a change to their provisional limit so that it takes
        account of particular institutional circumstances.




                                                                                                    8
Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




40. There will also be an opportunity to appeal for a change to the award of places from
the margin, once these have been confirmed.

41. Errors in institutions’ 2010-11 HESA or ILR data may affect the provisional student
number control limit that we have calculated. Specifically, this relates to:

       a.     The adjustments we have made for higher education institutions to exclude
       AAB+ equivalent students and those on first registrable medical and dental courses
       from the control. We do not expect responses from further education colleges relating
       to the identification of AAB+ equivalent students, because their adjustments are
       based on their HEIFES11 survey.

       b.   Our identification for both higher and further education institutions of the
       proportions of non-AAB+ equivalent students who are in SIVS.

42. Institutions wishing to correct 2010-11 HESA or ILR data are required to submit an
action plan by 17 February 2012 and to have signed off their data amendments by 2
March 2012. We will separately provide institutions, by 25 January, with further details of
how 2010-11 HESA and ILR data were used to inform the calculations, as well as the
process for submitting amendments to HESA or ILR data.

43. If you wish to appeal for us to take account of particular institutional circumstances,
any appeal must be submitted by Wednesday 8 February 2012. This should be sent to
your HEFCE Regional Consultant, <RCname> (direct line: 0117 931 <RCExt>; e-mail:
<RCmail>). Paragraphs 46 to 53 provide guidance for institutions wishing to appeal for a
change to their limit.

44. Places to be awarded following bids to the student number control margin invited in
HEFCE 2011/30 have not yet been decided or included in the provisional limits announced
in Annex A. They will be announced during the week beginning 30 January. If institutions
then wish to appeal for a change to the margin places awarded, the deadline for submission
will be the same as for other appeals – that is, by Wednesday 8 February 2012 and sent
as before to the HEFCE Regional Consultant. The letter announcing margin allocations will
provide more detail about the criteria for such appeals. This timescale is necessary to
ensure we are able to confirm student number control limits later that month.

45. We aim to confirm the student number control limits in the light of appeals, and
incorporating the outcomes of the margin bids, during the week beginning 27 February
2012. They will also be shown in the individual grant tables that institutions will receive on
19 March 2012. Our grant announcement will remain under embargo until 0001 on
Thursday 22 March 2012. Any changes to limits arising from corrections to HESA or ILR
data for 2010-11 are likely to be confirmed at a later date: the precise timing will depend on
our discussions with institutions about their data.




                                                                                                 9
Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




Guidance on appeals

46. There is no specified format in which an appeal should be submitted. Commonly
appeals take the form of a letter setting out the particular circumstances affecting an
institution, and specifying the action the institution would like us to take in response.

47. We expect appeals to be evidence-based and where appropriate, we will check
institutional claims for consistency with student data that we hold (such as HESES/HEIFES,
UCAS, the National Pupil Database, the Student Loans Company or HESA/ILR data). We
may reject appeals where the evidence provided by the institution is weak or inconsistent
with other data that we hold.

48. Institutions can submit appeals on whatever grounds they wish. This guidance is not
intended to limit the content of institutions’ submissions or to provide any kind of guarantee
of the acceptance or otherwise of an appeal. Each case will be considered on its merits,
although we will be mindful of the desirability of treating institutions consistently.

49. The 2012-13 student number control limits have been calculated using a baseline
derived from the equivalent limit for 2011-12. Those 2011-12 limits were finalised after
institutions had had an opportunity to appeal for changes. We are also considering
separately appeals for mitigation of grant adjustments for over-recruitment against the
2011-12 limits. Institutions should note, therefore, that grounds for appeal that have been
submitted and rejected before may be similarly unlikely to be accepted for 2012-13.

50. A small number of institutions were notified in previous years of fully-funded or
employer co-funded additional student numbers (ASNs), which they chose to phase into
2012-13. We have not increased student number control limits in order to accommodate
previously agreed 2012-13 ASNs: we believe the increases to limits provided up to 2011-12
for such phased ASNs should be sufficient to allow institutions to maintain entrants to the
courses concerned and thus recruit a further cohort. Institutions that wish to appeal for an
increase relating to ASNs previously announced for 2012-13 will need to demonstrate why
their existing limit is insufficient to accommodate them.

51. A number of changes have been made to the limits for individual institutions to reflect
the changed population that they now cover. These include:

       a.     A reduction relating to students known or assumed to have AAB+ equivalent
       entry qualifications. For higher education institutions, this has been informed by
       HESA data for 2010-11 and our linking to other data sources. Where we were unable
       to assign students unequivocally on the basis of institutions’ HESA data or our data
       linking to either the AAB+ equivalent student population or the non-AAB+ equivalent
       population, we have made assumptions about what proportion of such students will in
       fact fall within each category. Further information about this is provided in paragraphs
       16 to 19.

       b.   A reduction relating to students on full-time undergraduate medical or dental
       courses leading to a first registrable qualification for doctors or dentists. These have

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Provisional student number control limit for 2012-13: Annex C to letter of 20 January 2012




       been based on the number of Home and EU full-time medical or dental
       undergraduates that counted against the 2010-11 student number control limit
       according to 2010-11 HESA data.

52. Where institutions believe the adjustments we have made are incorrect as a result of
errors in their HESA or ILR data, they should correct that data. Where the underlying data
are correct, but institutions believe our calculations have resulted in an inappropriate
adjustment, for example, because of our assumptions about the treatment of students
whose entry qualification information did not allow us to assign them unequivocally to either
the AAB+ equivalent population or the non-AAB+ equivalent population, then they may wish
to submit an appeal. Any such appeal will need to provide convincing evidence why our
assumptions and/or calculations should be revised.

53. In considering appeals, we will be mindful of the fact that the student number control
limit:

       a.   Applies to all institutions, notwithstanding that many institutions might wish to
       respond to strong demand from students.

       b.     Applies to a strictly defined student population, which is not dependent on
       individual students’ claims for student support. The limits have been calculated to
       reflect the population they seek to cover, including, for example, students who
       withdraw from their studies after two weeks: if such withdrawals were not included in
       the population, we would set lower student number control limits.

       c.     Has been calculated for all institutions to incorporate adjustments relating to
       AAB+ equivalent students, medical and dental students and student numbers in SIVS
       that have been informed by data for specific years. This approach treats all
       institutions equitably and consistently. While we will be prepared to consider appeals
       relating to assumptions we have made where data for those years did not allow us to
       make unequivocal assignments of students, we do not expect to accept appeals on
       the basis that circumstances have since changed and that our calculations are no
       longer valid.

       d.     Follows the request we have received from BIS to reduce the risk of over-
       recruitment and to apply reductions for each excess student recruited. The rate of
       grant reduction for each excess student recruited will be determined following further
       guidance from BIS, applying the following principles:

             avoiding unanticipated pressures on BIS budgets
             removing any financial incentives for institutions to recruit above their permitted
              level
             recognising the different fees charged by institutions
             recouping an element to cover the costs of providing maintenance support.




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