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Skill-National-Bureau-for-Students-with-Disabilities

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Skill-National-Bureau-for-Students-with-Disabilities

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									Skill: National Bureau for Students with Disabilities DIUS Consultation: Single Equality Scheme
Skill: National Bureau for Students with Disabilities promotes opportunities to empower young people and adults with any kind of disability to realise their potential in further, continuing and higher education, training and employment throughout the United Kingdom. Skill works by providing information and advice to individuals, promoting good practice and influencing policy in partnership with disabled people, service providers and policy makers. Skill is a registered charity no. 801971, also registered in Scotland SC039212, and a company limited by guarantee no. 2397897 Skill welcomes the opportunity to respond to this consultation and is pleased that the Department for Universities, Innovation and Skills (henceforth referred to as the Department) has committed itself to building upon the equalities work of the former Department for Education and Skills (DfES). In particular, Skill hopes that DIUS will build upon the DfES’ Disability Equality Scheme, which was praised by a number of organisations for and of disabled people including Skill. Skill has a number of recommendations in response to this consultation. Skill’s response is designed to enhance and inform the further development of the process and recognises that as a new Department some areas of work are further forward than others. Skill’s response is directly related to the Disability Equality Duty and the need for a Disability Equality Scheme. The Department does of course have a duty which lies with the Secretary of State for Education and Skills to publish a report in December 2008. The Disability Equality Duty (DED) requires the Secretary of State to outline the progress that has been made in relation to disability equality in the education and skills sector and state how he proposes to coordinate action between public authorities to further progress disability equality.

Meeting the requirements of the Disability Equality Duty
Skill is delighted that the Department’s aim is not only to achieve compliance but also to demonstrate good practice in meeting the requirements of the Race, Gender and Disability Equality Duties. It is also pleased that the department aims to achieve an integrated and mainstreamed approach to equality and diversity. However, as it stands, the draft single equality scheme (henceforth referred to as the Scheme) does not meet some of the basic requirements of the Disability Equality Duty. In the development of the scheme it is vital that the Department makes explicit how it intends to meet the requirements of the DED, for example, the requirement to promote equality of opportunity for disabled people. While

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various initiatives are highlighted in the Scheme it is not clear how they are helping DIUS towards meeting its obligation to promote equality of opportunity for disabled people. Skill recommends that DIUS make clearer how its work promotes equality of opportunity for disabled people. To meet DRC/EHRC guidelines it needs to have a clear Disability Equality Scheme within the Single Equality Scheme and an identifiable DES Action Plan. Some good examples are the QCA and LSC Single Equality Schemes Specifically, Skill is concerned that the draft scheme does not make clear how disabled people have been involved to date in its development and how the Department will continue to involve them in the promotion of disability equality. The DED requires organisations to actively involve disabled people in the development of their disability equality schemes. Therefore, even though the scheme is a draft, involvement should be clearly evidenced at this stage. As emphasised in the Code of Practice ‘public authorities will be unable to identify and prioritise equality initiatives effectively unless disabled people … have been involved in that identification and prioritisation’1. Skill is aware of excellent examples of involvement that the Department has initiated such as the National Student Forum and the National Learner Panel, but these are general rather than specific and have not yet had a direct role in impact assessment. Skill hopes that the involvement of such bodies will be made more apparent in the Scheme. Skill recommends that the Department consider whether the involvement of disabled people to date fulfils the requirements of the DED, in doing so it should give consideration to the difference between consultation and involvement. It also recommends that the Department consider how it can better evidence the involvement that has taken place to date. In addition, while the Department’s commitment to and undertaking of equality impact assessments is mentioned, they are only mentioned in relation to policy development. The DED requires public sector bodies to impact assess its procedures as well as its policies. The Department does not state its method for conducting impact assessment and this is also a requirement of the DED. Furthermore, where policies are mentioned it is not clear whether they have been impact assessed, examples might include:  procedures relating to Student Finance Direct;  functional skills;  and the implementation of general qualifications covered by the DDA since September 2007. Therefore, Skill recommends that the Department outline its method for impact assessing its policies and procedures and makes clear in the Scheme where policies have already been impact assessed.
1

‘The Duty to Promote Disability Equality: Statutory Code of Practice, England and Wales’. The Disability Rights Commission, 2005.

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Data collection Skill has found that the following sources of evidence could usefully be employed in relation to disability:      Post-16 Transitions: A longitudinal study of young people with Special Educational Needs (2004 onwards) DfES Plasc data on SEN school secondary population Individualised Learner Record (ILR) HESA data on 1st year disabled undergraduates AGCAS data on disabled graduate destinations in employment

It is acknowledged that there are problems with ILR data on disabilities but it is still intended to use this to monitor impact by disability. Much reliance is placed on ILR data in the impact assessment, for example for PCDL evidence, evaluations of the impact of Train to Gain and Learner Accounts. Skill recommends that it is essential to review ILR data collection to ensure that it is robust and comprehensive before too much reliance is placed upon it to inform future policy and provision. Employment destinations for disabled people should be part of the required data from the new adult careers service.

Further Education and Skills
The Commission for Disabled Staff Skill is pleased that the Department makes specific reference to the work of the Commission for Disabled Staff in the Scheme’s action plan. The work of the Commission was of particular importance to Skill as today’s students (disabled and non disabled) may well be tomorrow’s disabled staff. However, unless steps are taken to improve provision for disabled staff in further and higher education institutions, talent will be lost to other parts of the education sector and other industries. As the Commission has made its final report, Skill recommends that the Department work towards implementing the recommendations of the Commission and commits itself to working with the equality implementation group that has been convened by Lifelong Learning UK rather than monitoring the work of the Commission. LSC and Funding methodology for learners with learning difficulties and/or disabilities This scheme relies heavily on the work of the LSC on Equality and Diversity. Indeed the LSC is to be commended on the depth and quality of its work in this area. Skill recommends that DIUS ensure that the guidance and policies developed and published by the LSC be captured and not lost when it is closed.

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Other specific initiatives: National Improvement Strategy Skill welcomed the improvement strategy and the development of coherent vision for the FE system. The demands of learners and the economy will change over time and an excellent FE system will need to constantly evolve to meet these changes. Skill recommends that the QIA/LSIS work with senior managers, principals and governors of providers to ensure that disability and other equality and diversity issues are high on the agenda. Train to Gain The Train to Gain initiative could be used to maximise equality and diversity through the leverage of funding for the LSC. Disabled people are doubly disadvantaged in accessing this funding as prejudice in recruitment has already taken place by employers ( as DRC employment figures show). The DIUS scheme action plan needs to show specifically how the impact of this funding policy on all learners can be measured and action taken in relation to under represented groups.

Progression Through Partnership Skill welcomed Progression Through Partnership when it was published as providing a joint strategy for meeting the needs of learners with learning difficulties and/or disabilities with support from key government departments. Skill strongly believes that the strategy set out in Progression Through Partnership must be implemented and is willing to support the departments in developing a Delivery Plan. Skill believes that reforming the 14-19 sector and funding for learners with learning difficulties and/or disabilities must continue and the momentum of successful reform should not be put on hold while other changes are implemented. This is a major piece of work for the Department to implement but the action plan reference to this is currently minimal. Skill recommends that a full statement of implementation of Progression Through Partnership appears in the Action Plan.

National Learner Panel Skill recommends the government identifies clear pathways for disabled learners’ views to be represented on the National Learners Panel and ensures the LSC will review arrangements for the national customer satisfaction survey, to ensure all disabled learners including those outside discrete FE provision are included. The scope of the LSC National Learners Panel for Learners with learning difficulties and/or disabilities and its relationship to the DIUS National Learners Panel mentioned on page 15 needs to be transparent in the DIUS involvement strategy in its Disability Equality Scheme. This should linked within the DIUS and LSC Disability Equality Schemes and be clearly reported on.

Higher Education
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Gateways to Professions Skill welcomes DIUS’s commitment to improving graduate level access and retention in the professions and the initiatives that it is supporting through the Gateways to the Professions Development Fund. In Skill’s experience significant barriers remain for disabled people wanting to achieve professional qualifications and enter a profession. Skill has produced aspiration raising guides to encourage disabled people to enter certain profession, that are traditionally perceived to be closed to them (visit www.skill.org.uk for further information on the ‘Into’ series). Despite the initiatives of Skill and other organisations such as the GMC and the TDA, to increase awareness of the ability of disabled people to enter professions our free helpline continues to receive reports of disabled students being unable to qualify to enter their chosen profession due to fitness to practice regulations. Skill recommends that DIUS includes in the Schemes action plan the initiatives it has introduced or plans to introduce in response to the DRC’s formal investigation into fitness to practice in the nursing, teaching and social work professions2. The report of the formal investigation makes recommendations for the former DfES, professional bodies as well as higher education institutions.

Funding for Disabled Students Disabled people are under represented in the higher education sector and access to DSA has been linked to improved access and retention of disabled people in the higher education sector3. DSAs have been significantly increased and Skill has welcomed this improvement. However, there is scope for DIUS to promote equality for disabled people by reviewing some students DSA entitlements for example: Part-time students As highlighted in its response to the recent Higher Education At Work consultation, Skill hopes that DIUS will explore ways in which it can support students, who for reasons relating to their disability need to take longer than three years to complete their degree. At present students who complete their course in less than 50% of the full time equivalent are not eligible for Disabled Students Allowances. Post-graduate students. In addition, Skill also hopes that DIUS will review the amount of DSA available to postgraduate disabled students. Post graduate students who do not have a research council award are significantly lower than undergraduate DSAs. Yet postgraduate courses are likely to be more intensive than undergraduate courses. In addition, postgraduate DSA is partly designed on the assumption that recipients will have recently undertaken an undergraduate qualification.
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‘Maintaining Standards: Promoting Equality’ Disability Rights Commission, September 2007 ‘Staying the course: the retention of students on higher education courses’ House of Commons Committee of Public Accounts, Tenth Report of Session 2007-2008, February 2008.

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For the academic year 2008/2009 postgraduate DSA is £10,000 per year whereas undergraduates can claim £5,030 for specialist equipment and up to £20,000 per year for non medical help. In addition they can claim up to £1,680 year for general costs arising as a result of their impairment and travel, for which there is no limit. The difference between postgraduate and undergraduate DSA has been recognised in Scotland and postgraduate DSA rates are now the same as undergraduate DSA rates. Research Councils also award DSA at the same level as the undergraduate rates. Skill recommends that DIUS commits itself in its Single Equality Scheme to a review of DSAs for part time and post graduate students.

Science Policy and Innovation
Skill is concerned that the actions in relation to widening participation in science and innovation profession primarily focus on gender and race. As highlighted in a recent report by CaSE4, the Campaign for Science and Engineering in the UK to which Skill contributed, disabled people currently make up just 3.8% of the science, engineering and technology (SET) workforce compared with 5.9% in other sectors. Skill recommends that DIUS reviews its work with the FE and HE sectors and professional bodies to improve accessibility of Science subjects for disabled people. For example, it could extend the Gateways to Professions project, which in the case of the General Medical Council has already had a significant impact. In addition to monitoring progress towards increasing the numbers of girls and ethnic minority school children engaged with science, Skill recommends that DIUS monitor the number of disabled school children engaged with science. Skill also recommends DIUS ask QCA for a report on how it is promoting access to science examinations for disabled candidates under the General Qualifications section of Part 4 of the DDA which came into force in September 2007, for example GCSEs, 14-19 Diplomas, ‘A’ levels.

Expanding the scope of the Departments equality work
Skill is pleased that the department intends to expand its equality work to cover age, sexual orientation, religion or belief and gender identity. This is particularly prudent given the Government’s proposals outlined in the ‘Framework for a Fairer Future – The Equality Bill’. While Skill recognises that at this stage the Department needs to compile an evidence base from which it can progress its work on these equality areas, Skill
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‘Delivering Diversity: Making Science and Engineering Accessible to All’ CaSE Policy Document No. 8 May 2008.

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recommends that the Department make a commitment in the Scheme’s action plan as to how and who this will involve and the processes that will deliver it.

Skill Policy Team July 2008

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