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									Skill Scotland’s response to Scottish Funding Council consultation
SFC/03/2006
Review of college and HEI teaching funding methodologies

Skill Scotland: National Bureau for Students with Disabilities promotes opportunities
to empower young people and adults with any kind of disability to realise their
potential in post-16 education, training and employment across Scotland. Skill
Scotland works by providing information and advice to individuals, promoting good
practice, and influencing policy in partnership with disabled people.

General comments
Disabled students make up a significant proportion of the student population in
Scotland – in 2004-05, almost 13% of college students and 5.6% of university
students declared a disability1. Given that disabled people with no qualifications are
twice as likely to be unemployed as non-disabled people with no qualifications2, it is
vital that the funding methodology for colleges and universities takes adequate
account of the additional costs of provision for disabled students, to ensure that there
are no barriers to participation in post-school education.

Skill Scotland‟s response to this consultation will therefore largely focus on the
disability aspects of formula funding in both further and higher education.

Section one: draft funding principles
Skill Scotland broadly agrees with the suggested funding principles, but would
suggest that a further principle, „consistency‟, should be added. Given the merger of
the Funding Councils, any future funding methodologies should ensure that, where
appropriate, consistent principles are applied in the methods of allocating funding to
colleges and higher education institutions (HEIs).

For example, the principles regarding teaching funding allocations for providing
materials and services to disabled students differ between colleges and HEIs.
In colleges, such funding is allocated on the basis of any student who falls into a
specific disability category and subsequently requires additional support measures.
In contrast, the funding awarded to universities is based on the number of students
who receive the Disabled Students Allowance (DSA), thus ignoring those disabled
students who have additional support needs but are not eligible for DSA.

Such a system has the potential, in theory, to discourage universities from accepting
applications from disabled students who are not eligible for DSA (such as
international or part-time students) as they will not attract premium funding but will
nevertheless require financial support from the university to meet their disability-
related support needs. Skill Scotland would therefore recommend that the funding
principles between colleges and universities in this area should be consistent by
allocating funding on the basis of need rather than funding categories. Any such
review of premium funding in HEIs could usefully build on the current work in the


1
    Scottish Funding Council, 2006
2
    Labour Force Survey, winter 2004-05
college sector which seeks to introduce a „needs-led‟ model of funding for students
with additional support needs.

Skill Scotland would also suggest that the principle [capable of] „promoting equality‟
should be added to the draft funding principles. From December 2006 all colleges
and universities, as well as the Scottish Funding Council, will be subject to the new
Disability Discrimination Act: Disability Equality Duty (DED). This legal duty requires
all public bodies to promote disability equality across all organisational functions and
to develop a proactive approach to disability equality in all current and future policies,
practices and procedures. The Funding Council will therefore need to assess the
impact of any proposed changes to the funding methodologies to ensure that
disability equality is considered throughout.

Similarly, such a principle would apply to other legal duties upon public authorities
regarding race (the Race Equality Duty, 2005) and gender equality (the forthcoming
Gender Equality Duty, 2007).


Section two: views on current funding methodologies

Further education
Although we have already commented on proposals to develop a needs-led funding
model in colleges in an earlier SFC consultation (SFC/01/2006 C), Skill Scotland
would like to offer the following comments.

Meeting students’ needs through core funding
The above consultation proposes a system of support based on allocating Extended
Learning Support (ELS) to the activity of those students who fall into the highest
„level of need‟ in a support grid. For those students who do not fall into this category,
colleges will be expected to meet such students‟ needs through good organisational
inclusive practice. While Skill Scotland supports a system which encourages
colleges to meet additional needs within the norm of provision, we are concerned that
without an increase in core funding, such a system could result in some colleges
rejecting applications from students with additional support needs if there is no
guarantee that they will be able to draw down ELS to meet their needs.

Skill Scotland therefore suggests that core funding is increased, to allow colleges to
further develop inclusive practice, and that the funds claimed against ELS are ring-
fenced, to ensure that the funds are used for the purpose given.

Review of weightings
While Skill Scotland strongly supports any proposals for colleges to move towards a
system where additional needs are met within the normal provision, there will always
be some needs than can only be met on an individual basis. It is important that the
funding for meeting such needs is adequate to ensure that students with disabilities
and other additional support needs are not discouraged from participating in learning.
Skill Scotland would therefore recommend that, following the outcomes of the needs-
led consultation, the Funding Council should carry out a review of the adequacy of
the current ELS weighting.
Such a review should include an assessment of:
    the likely change in student numbers qualifying for ELS under the proposed
      „needs-led‟ model compared to the current approach
    average costs for certain identifiable needs, such as British Sign Language
      interpreters, transcription and personal (education-related) assistance
    current procedures among colleges for paying for diagnostic assessments for
      dyslexia for students applying for the DSA. Currently, hardship funds are
      sometimes used to pay for these assessments but this diverts hardship funds
      from their intended purposes. ELS funding should be of an adequate level
      that it will cover the costs of these assessments where needed
    circumstances where DSA has not entirely met the needs of HE students and
      colleges have had to make up the difference. Skill Scotland would
      recommend that it would be useful for the Student Awards Agency for
      Scotland (SAAS) to produce clear guidance on what DSA can and cannot pay
      for in order to allow colleges to adequately meet their responsibilities under
      the DDA.

For DPG 18 programmes, Skill Scotland would suggest that rather than increase the
weightings for this type of provision, colleges should be able to claim ELS for
students on such courses who require substantial additional support. As well as
avoiding the need for a separate pot of money to fund such students‟ needs, this
would also reduce the need for a review of the weighting for DPG 18 programmes.


Higher education

Disabled Students Premium funding
Skill Scotland is concerned that the method of distribution for the Disabled Students
Premium (DSP) does not accurately reflect the level of disability-related costs in
universities. DSP is currently determined by the number of students receiving DSA
in each institution, as reported by the institution to the Higher Education Statistics
Agency (HESA). There are a number of difficulties with this method of distribution,
including the following:

       Using DSA as the method of distribution does not take account of the
        fact that there are more disabled students in universities than there are
        recorded DSA recipients.
        A recent Scottish Executive statistics publication3 showed that in academic
        year 2004-05, 5.6% of students in Scottish HEIs declared a disability. Of
        these, only 32.5% were in receipt of DSA, 42.7% declared a disability but did
        not receive DSA, and 24.8% declared a disability but no information was
        known on their DSA status. Students who are not eligible for, or do not
        receive DSA, will nevertheless have the same disability-related costs but do
        not attract any funding. As a result, funding calculations for 2006-07 disability


3
 ‘Statistics on students in higher education at Scottish universities and colleges during the
academic year 2004-05’ (Scottish Executive: May 2006).
       premium funding would only take account of 32.5% of the disabled student
       population.

      Data supplied to HESA on students receiving DSA has proven to be
       unreliable for funding purposes
       The data submitted by institutions to HESA regarding DSA recipients is based
       on the self-declaration of those students who inform their university of the
       success of their DSA application. As SAAS do not inform institutions if a
       student has been successful in their DSA claim (unless the institution is an
       accredited assessor – currently only 5 institutions and 9 pilot institutions), it is
       unlikely that institutions will be able to provide an accurate record of the
       number of students who receive DSA.

      The link between DSA and DSP could be perceived to provide a financial
       disincentive for institutions to provide support for disabled students as
       part of their overall provision
       Unlike the system of support in colleges, DSA is for individual needs. While
       Skill Scotland agrees that an individual system of support is more appropriate
       in universities, attaching DSP to individual funding provides no incentive for
       institutions to make their overall provision inclusive, as to do so would result in
       less students applying for DSA and subsequently less premium funding for the
       institution. This is contrary to Part 4 of the DDA which places an anticipatory
       duty on education providers to make reasonable adjustments whenever a
       disabled person is placed at a substantial disadvantage.

      Disability premium funding often has to meet individual student support
       costs
       Although DSA is intended to allow the individual student to purchase their own
       support arrangements, given that a significant number of disabled students
       are not eligible for DSA (42.7% in 2004-05), it is likely that institutions will be
       required to meet these students‟ individual support needs through disability
       premium funding. As a result, institutions could be discouraged from enrolling
       disabled students who are not eligible for DSA as they do not attract premium
       funding and do not receive individual funding to fund their own support needs.
       In addition, institutions will also be expected to use their premium funding to
       support those students who have reached their DSA maximum (such as those
       requiring expensive equipment or sign language interpreters), as well as
       meeting their legal responsibilities under the DDA to ensure that their physical
       estates and services are accessible. If DSP continues to be linked to DSA, it
       is unlikely that institutions will be able to meet these costs.

As such, the current system of allocating disability premium funding to HEIs appears
to fit uneasily with the draft funding principles, which state in paragraphs 18 and 19
that “[a funding methodology] should allocate funding without any unintended
consequences and the that funding should reflect as far as is reasonably possible the
costs of delivery taking into account diversity of institutions and provision…. We
need to ensure that we do not inadvertently develop a methodology that significantly
risks the viability of certain types of provision or delivery compared to others.”
Options for changing the allocation method for DSP
Skill Scotland would urge the Funding Council to give consideration to robust,
appropriate methods of distributing the Disabled Students Premium which will
encourage the further inclusion of disabled students. As well as taking into account
the issues raised above, any possible options for an alternative method of distribution
should make use of reliable and accurate data, and should involve as little
administrative burden as possible for institutions.

We are aware that various options have been considered by the Council in the past,
including distribution on the basis of HESA data, distribution on the basis of students
registered with each institution‟s Disabiltiy Office, and the introduction of a
standardised data collection form. Given the complexity of this issue, Skill Scotland
would suggest that any options for change should be considered as part of a long-
term review rather than a „quick fix‟ solution. We would therefore recommend that a
short-life working group is established to consider alternative methods of allocating
this premium. Skill Scotland would be pleased to assist the Funding Council in any
future developments regarding this issue.


Cross sector issues
From December 2006 all colleges, universities and the Scottish Funding Council will
be subject to the new DDA Disability Equality Duty and will therefore be required to
promote disability equality. As well as a general duty to promote equality of
opportunity and positive attitudes towards disabled people, all institutions will be
required to adhere to the specific duties of the regulations, including the publication
of a Disability Equality Scheme (DES) every 3 years.

The new legislation introduces general and specific duties to promote disability
equality across all institutional functions. This will require colleges and universities to
be proactive about how they mainstream disability equality to ensure that they build
disability equality from the start into everything that they do. Whereas previous
legislation, the Special Educational Needs and Disabiltiy Act (1995), gave disabled
students new rights in education and placed a duty on institutions to make
reasonable adjustments, the Disability Equality Duty goes much further. The new
duties require all institutions to eliminate institutional discrimination and to develop a
proactive approach to making a positive change to the lives of disabled people, not
just students, by promoting disability equality in all policies, practices and
procedures.

The implications for teaching funding for institutions are likely to be significant,
including:

      ensuring that disability-related issues are built into resource allocation
       policies
       As well reviewing the obvious disability-related funding premiums, the Funding
       Councils, colleges and universities will need to ensure that existing or future
       funding policies do not adversely affect disabled people. For example, in
       2003-04, the Funding Council revised its fee waiver policy in both FE and HE
       to include Disability Living Allowance as a qualifying benefit. This revision
       ensured that disabled students who received this benefit were automatically
      entitle to a fee waiver in recognition of the fact that disabled students often
      face significant barriers in accessing post-school education.

     data collection on the number of disabled students at each institution
      The new duties will require institutions to collect more robust data on the
      number of students who enrol, progress and complete a course of education
      at each institution. Institutions are therefore likely to require additional
      resources to ensure that they can accurately identify the proportion of disabled
      students (and staff) at their institution, as well as collecting data on how their
      provision takes account of the needs of disabled people. As well as using this
      information for future planning purposes, such data could also be useful in
      terms of gaining a more accurate picture of the number of disabled students in
      HEIs for the purposes of allocating the Disabled Students Premium.

     conducting impact assessments of existing policies and procedures
      Colleges and universities will be expected to assess and prioritise the impact,
      or likely impact, of all existing and new policies and practices on disabled
      people. This could include reviewing the impact of specific part of the current
      funding methodologies on disabled people, and the impact of any proposed
      changes.

     Anticipating the needs of disabled students in the design and delivery of
      courses
      The Disability Equality Duty requires public bodies to proactively promote
      disability equality in all aspects of their provision. In addition, Part 4 of the
      DDA requires education providers to anticipate what sort of adjustments may
      be necessary for disabled people in the future and, where appropriate, make
      adjustments in advance. Colleges and universities will therefore be required
      to review, and where necessary redesign, course delivery to ensure that all
      provision is fully accessible. In addition it will be necessary to equip academic
      staff with the skills to deliver teaching in an accessible and inclusive format.
      As a result, institutions are likely to require additional resources for Disability
      Equality Training for all academic staff, training in „Teachability‟ and other
      specialised training such as deaf awareness or mental health training. In
      addition, institutions will have further duties towards meeting the needs of
      students who do not qualify for public funding.


Summary of recommendations

     The draft funding principles should include a reference to „consistency‟ to
      ensure that, where appropriate, consistent funding principles are applied in
      colleges and HEIs.

     The draft funding principles should include a reference to „promoting equality‟
      to ensure that equality issues, including disability, are given consideration
      throughout the funding review.
      Should the proposals in the „needs-led‟ consultation be adopted, there should
       be an increase in core teaching funding for colleges to ensure that colleges
       can develop inclusive practices.

      The Funding Council should review the weighting for ELS, and colleges
       should be able to claim ELS for students on DPG 18 programmes.

      A short-life working group should be established to consider alternative
       methods of distribution for the Disabled Students Premium.

      The Funding Council should conduct an impact assessment to measure the
       likely impact of any changes to the funding methodology on disabled people.


Skill Scotland welcomes the opportunity to contribute to this consultation and we
would be pleased to assist the Funding Council in future developments affecting
students with disabilities.


                                                       Skill Scotland 17th August 2006

								
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