What happens if an institution has more students who have accepted offers than the student number control issued?
Where a provider has more students having already accepted offers than their student number control allows, they will not be subject to reduced fee limits/fee loan amounts as a result of this because their SNC level is increased to this level. However if some students do not enrol or withdraw before enrolment a provider may not recruit more students to replace them unless their recruitment drops below their original student number control. DfE has an example in their further guidance to explain more. For more information see the Department for Education’s Student Number Controls Further Guidance.
Will students transferring to a new provider be considered as part of the new provider’s student number control?
Yes. Students entering directly into the second or later year of a course through student transfer will be included. A student is considered a new entrant if the higher education course is recognised for funding and the student has not been learning at the same broad level in the previous two years at the provider.
How are student number controls calculated for those providers who had not yet submitted an annual financial review (AFR) or did not have their AFR approved by 4th May 2020?
Providers who have not submitted an annual financial review will receive a cap based on their previous year’s entrants, plus 1.5% (instead of the forecast in your AFR) plus 5%.
Are students taking exams for a vocational level 3 qualification in autumn 2020 counted as new entrants and therefore part of the student number control?
No. All students taking exams for level 3 qualifications in Autumn 2020 are exempt from the student number controls and will not be counted within the control. This includes vocational qualifications.
Will student number controls apply to providers transitioning from ‘Approved’ to ‘Approved (fee cap)’ status?
Only providers who were registered as Approved (fee cap) by 4th May 2020 will be subject to the current temporary student number controls.
Will the OfS take decisions about what an appropriate financial discount is for online alternative provision by OfS registered HE providers?
No. The OfS has commented in their guidance on this issue but will take no decisions itself. If a provider is planning to offer a discount, the provider needs to be specific about the time period the discount will apply to. The decision to apply a discount, and the level of that discount, is the responsibility of the provider. For more information see the OfS Guidance for providers about student and consumer protection during the coronavirus (COVID-19) pandemic
If a student arrives in the UK before 6th April 2021, but has already completed some of their final semester online, are they still eligible for the Graduate Route launching in 2021?
The Home Office has confirmed that as long as they are in the UK by 6th April and conduct some of their study whilst physically in the UK they will fulfil that specific part of the criteria. For more information see the Covid-19: Guidance for Tier 4 Sponsors and Migrant sand for Short-term students
Students now have a 6 month window to make applications. For most courses this means that the date can be the course start date, however if it is likely that the student will be studying online for more than six months, providers may wish to put the date of the in-person part of the course. The Home Office is aware that this could cause an issue for BRP production and collection, and are exploring potential solutions.
Has the Government updated guidance for Tier 4 sponsors and migrants, and for short-term students, in relation to distance and blended learning?
Distance and blended learning will be permitted for the 2020/21 academic year provided students intend to begin face-to-face learning as soon as circumstances allow. Any student studying by distance and blended learning will be eligible to apply for the Graduate route provided they are in the UK by 6 April 2021 and complete their final semester of studies in the UK.
Does OfS expect providers to increase or introduce additional academic or well-being support to students over the levels they offered before COVID-19?
Providers should do what they can to support students during this difficult time, focused on what is appropriate for their students and reasonable for the provider to deliver. If a provider doesn’t offer specific support, their approach could include signposting students to similar support available externally, particularly for those students who might be facing mental health difficulties. If a provider does have their own provision, they may consider moving these sessions online. OfS does not have an expectation that providers start offering support they wouldn’t ordinarily offer. They also acknowledge that those with their own provision might be under more strain, so providers should endeavour to offer what they reasonably can and keep students informed about any changes to services.
The latest Quality and Standards Guidance states that whilst it is unlikely that any student protection plan covers actions to be taken in current circumstances, providers should follow the broad principles which are set out in individual plans and have been committed to in regards to changes in courses. OfS expects that providers “make all reasonable efforts to deliver any commitments in their student protection plans that are relevant.” However, providers do not need to amend or revise their current plans.
Members with financial end of years at the end of December have to submit their audited accounts to OfS by the end of May. However, some are finding that during this current uncertainty their auditors are not prepared to audit the accounts. OfS recognises that this may be an issue for some providers. They have said that providers will need to submit their information in the normal way, with OfS anticipating that the accounts will be signed off by auditors. If providers are facing challenges in getting the accounts signed off, then they should get in contact with OfS directly to discuss their case and decide a way forward.
‘No detriment’ or ‘safety net’ policies have been introduced at a number of institutions across the country and outline the institutions approach to assessments where students will not receive a final grade that is less than their current performance on that unit, module or course. In the latest Quality and Standards guidance from OfS, they have noted that “such approaches are likely to be appropriate, particularly to reduce pressure on students in the current difficult circumstances. Individual awarding bodies should, however, ensure that standards remain secure as set out in the sections that follow.” Providers with their own Degree Awarding Powers, or who award their own qualifications might consider if a policy like this is an appropriate approach for their own students. It is important for providers who teach courses awarded by another institution or body are in close communication with their awarding partners to understand if these are being implemented at the partner and what expectations the partner has for their validated or sub-contracted provision. In all cases providers should communicate clearly with students any changes to their assessments or student outcomes.
How are members managing auditions, interviews, portfolios and other submissions in their admissions process, where they are already part of the process? Has the moratorium on unconditional offers changed the way you make offers to these students?
Many members use auditions, interviews, portfolios and other submissions as part of their admissions processes alongside traditional academic qualifications. Members on Wednesday’s call said that they normally review these portfolios as part of the interview process, which for some has already taken place. Some have given student conditional offers as they still require academic results. Other members would normally put more focus on these additional submissions or have mature students who will have already completed their academic qualifications and as a result would normally offer more unconditional offers as part of their contextual admissions process. The moratorium on unconditional offers has caused some to have to pause all offer making as it would be unfair to students to make a conditional offer, where they had given an unconditional offer to an applicant who was able to meet the conditions of admission before the moratorium was imposed.
QAA encourages providers to be flexible and consider a range of metrics in their admissions processes for 2020-2021 and flag any changes with students. Providers building in new elements to their processes or changing existing criteria should “carefully consider the feasibility of such assessments in the current environment and the different needs of students, again giving special attention to internet access and the requirements of students with additional needs.” The Office for students encourages providers to ensure their admissions processes are fair and robust. IHE members with additional requirements such as professional exams are exploring “trailing” some of their entry requirements and requiring students to complete these exams (which have been suspended at the moment) in the first semester of their studies. This trailing of entry requirements can be successfully done if there is support for these students if they don’t pass the exam they are required. Other IHE members have suspended the submission of some elements of their admissions process as students may be unable to complete their applications. Members should seek professional advice where the trailing of entry requirements are a legal or regulatory requirement such as English language testing, or where they may be required by a professional standards body as part of an accredited course.
Where should providers be going for advice on the standards of international qualifications that may have been changed due to Covid-19?
UCAS have published some information about international qualification standards on their information pages for students. UK NARIC has pulled together a more comprehensive guide to known impact to education and qualifications across the world which members can refer to when assessing qualifications presented by international students. The British Council have been providing updates on the education situation in different countries and their briefings can be accessed via their website. Please note you will need to log-in or sign up for these briefings which are available to UK education providers.
Some EU and non-EU international students are facing considerable financial hardship as they are not eligible for any of the funding schemes and prevented from working due to the pre-2019 visa restrictions for students attending private providers. Where students are in your validating or sub-contracting partners residence or in student accommodation owned by one of the large companies, we would encourage you to get in touch with them to see what support they can offer these students. This may be able to relieve some financial pressure on these students. Many are allowing students to leave contracts early and see more affordable accommodation or travel home. You should consider encouraging students to leave the UK where they can as they can continue studying from home. Students must be reminded that if their visa conditions say they are not permitted to work while in the UK, they must adhere to them. Some London-based Embassies are reaching out to students to help where they can, and providers should encourage their students to contact their embassy to see what they can offer. Providers should also contact their local food banks to see if their student support services can act as a referral point to support students who may require this support. We will make the Universities Minister aware of the difficult financial situation for these students, and the potential that many will be unable to get finance from home as their own countries go into lockdown.
Many students, especially in the creative industries, work freelance and would be classed as self-employed but are now not able to gain an income. Some will be eligible for support but others will not sue to the inclusion of the student maintenance loan. For those students who are self-employed and are eligible, they can apply for the Income Support Scheme which supports the self-employed up to 80% of their monthly earnings with a cap up to £2,500. This will be based on tax returns from 2016-17, 2017-18 and 2018-19. The criteria also include that those applying have trading profits of less than £50,000 and more than half of your total income come from self-employment. They may be some situations where students are not eligible for the scheme or if the student maintenance loan is considered as income. In this case they may be deemed ineligible if their self-employed income is less than their loan income. We are looking into this issue and will bring it to the attention of the Universities Minister.
Where can students who are struggling financially and are ineligible for universal credit get financial support?
We understand that many students are struggling financially as they are in their final year and not eligible for a final maintenance payment from SLC. If students already have a part-time job, but are not working due to Covid-19, they may be eligible to receive support from their employer through the Job Retention Scheme. Please encourage students in this situation to contact their employers about the different schemes available to see if they are eligible and can continued to get paid during this time. We will also raise this issue with the Universities Minister, particularly for those students whose only option is a universal credit payment which they are not eligible.
OfS have announced that they are suspending requirement to submit transparency information in April 2020, and withdrawing the requirement to do so that was set out in the F1 Notice issued on 19 February 2020. Instead they will draw on HESA and ILR data to publish a reduced set of transparency information during this period. For providers that have already made a submission OfS will not undertake any further work on this or require any further information. The requirement to publish transparency information in June 2020 is suspended.
Do we need to put a note on the CAS in the SMS if a student is not travelling to the UK but starting their course online?
The Home Office has set out their expectations for Tier 2,4 and 5 sponsors in light of Coivd-19. Providers do not need to put a note on the CAS for students returning back to their home country to study online as sponsors do not need report those engaged with distance learning methods. These arrangements will apply until the 31 May when these will be reviewed. Sponsors must report as usual if the student permanently withdraws from the course.
What will be the impact for students or staff who are unable to leave the UK due to COVID-19 and then overstay their visa?
The Home Office has released guidance confirming that non-EEA nationals who are in the UK and who have overstayed, or will do so, because they cannot leave due to coronavirus will be able to ask the Home Office to extend their leave to remain until 31 May 2020. Visa nationals should contact the Coronavirus Immigration Team (CIT) by email CIH@homeoffice.gov.uk, with the information requested in the guidance above to request an extension. The guidance was updated on 27 March to outline that Home Office will reply to emails within 5 working days. The Home Office Factsheet published 24 March states that this period of overstay will not be counted in future applications: “The Coronavirus Immigration Team will update relevant details on UKVI databases. Individuals will be advised that UKVI have noted their details; they will not be subject to enforcement action; and this period will not be held against them in future applications.” UKCISA also address this question and will be keeping their pages updated with the most recent guidance from the Home Office and UKVI.
Our commercial partners Carter Thomas have posted a helpful overview of attendance monitoring in light of the COVID-19 pandemic. They outline the UKVI guidance that they will not take action against sponsors if they do not report a students’ (or staffs’) absences if they are due to COVID-19 and the sponsor has decided to continue sponsoring them. The Home Office Tier 4 Policy team will be releasing new guidance on attendance monitoring in the near future which will allow providers to set their own definitions for when students are “engaging with their education” which will replace the current 10 contacts model. We anticipate this will address the issue of providers having to change their “contact points” in light of a move to online delivery however there is no existing guidance to address this change. IHE will ask the Tier 4 policy team this question and get back to members with a response.
If a student has been granted immigration permission in the UK recently but not yet received their biometric residence permit (BRP), that student can still leave the UK. If the BRP is not collected it will be cancelled and cannot be used by the student. A student may re-enter the UK with a single use application and then then apply for a replacement BRP when they return to study. More information can be found in the UKCISA pages.
QAA has outlined in their initial guidance that switching to online learning is not simply a matter of moving the type of delivery and number of hours from your in-person delivery to an online model. Providers should ensure they balance the delivery of teaching with the needs of the student and subject. Some aspects of your course delivered in-person may not be possible online and it might be more practical to defer these until they can be delivered in-person. Section 1 “Learning and Teaching” of the above guidance outlines some key things to consider when balancing the amount of teaching you do in-person with what can be done online.
CMA have published additional information about their response to businesses approaches to Covid-19 and how existing rules apply. They are also establishing a dedicated Covid-19 taskforce to monitor activity in this situation and advise government on how to ensure competition law doesn't stand in the way of public health. IHE have asked the Office for Students to work with CMA to create better guidance for HE providers to address those who have switched to online classes.
We have contacted the Department for Education to request further information on behalf of members providing teacher training and will keep you informed when they respond. In the meantime sector body NASBTT has posted some very helpful information, including FAQs on virtual teaching and ITT criteria. GTC Scotland and the Scottish Council of Deans of Education posted their contingency plans on 16 March 2020.
The Universities Minister, and the Office for Students, has made clear that HE providers must pause unconditional offers for two weeks whilst Ofqual is developing the calculated grade process for GCSE, AS and A Level qualifications. Providers are encouraged to be flexible and reasonable during the admissions cycle. UCAS have stated that they expect the admissions to run broadly the same as previous years. All UCAS events have been postponed until 31 July. UCAS has extended the May offer deadline for UCAS undergraduate applicants and implemented rolling decision dates for UCAS Teacher Training applicants and providers which may have an impact on Clearing processes. We are communicating with UCAS and will update members when we know more about Clearing 2020. IHE Commercial suppliers EMSI have published a blog on their analysis of the labour market data so far and what they can do in the future to establish if we may see a boom in mature students or those coming back to study from the labour market following redundancies and a slow in hiring as a result of the crisis.
What should providers do without their own accommodation to support students in private rented accommodation?
We appreciate that most members do not have their own accommodation and many of their students are in private halls of residence or private rental properties. If you do have partnerships with private halls of residence, we encourage you to work with the management to support your students and have clear communications to these students on what they should do if they are currently in halls. The Coronavirus Bill has set out a number of details regarding private renting which members should consider. The Bill states that no new court proceedings for eviction can commence in the next three months (and might be extended). Student Services teams should work with your existing partners, including the third sector organisations such as Shelter, to make sure any information is correct. Please note, members should not be giving legal advice to students on accommodation, but refer them to appropriate organisations who can support them. The National Union of Students have published an article on WonkHE outlining what providers can do to support students in private rented accommodation. These include:
- For those staying in private student accommodation which has been recommended or contracted by the provider:
- Make sure the accommodation provider is aware of the government’s advice on non-eviction, and encourage them to follow it.
- Negotiate with companies to let students out of leases early with no penalty if they have already travelled home.
- Ensure there is clear information to all students regarding staffing, repairs, cleaning, inspections, viewings etc
- Supporting students with health conditions that make them more at risk to relocate to a more isolated part of their accommodation (such as a studio flat or en-suite room)
- Ensure all students are getting the most up to date public health advice, and what support is available from the provider. This could include advice on how to manage in a House with Multiple Occupancy (HMO).
What are the rules for international students and staff who cannot leave the UK at the end of their visa?
The Home Office released new guidance on 24th and 25th March 2020 that confirms that non-EEA nationals who are in the UK for short-term stays (including short term study visa holders) and who have overstayed, or will do so, because they cannot leave due to coronavirus will be able to ask the Home Office to extend their leave to remain until 31 May 2020. Importantly this is not granted automatically, and those who need to stay must contact the Coronavirus Immigration Team: Email: CIH@homeoffice.gov.uk. Your email must be in English. Telephone: 0800 678 1767 (Monday to Friday, 9am to 5pm) Our commercial partners Carter Thomas have posted an overview of the guidance on their website.
Can international students who would have had to go home to apply for a new visa now do this in the UK?
How will OfS approach quality assurance and regulation with the uncertainty facing students as a result of the crisis?
Whilst some regulatory requirements have been suspended, the latest letter (25 March) from OfS set out that one of the three objectives still in place is that they will “protect students by working with providers to develop practical ways to maintain teaching quality and standards, enable adequate exams and assessment, and support financial sustainability.” They will be providing further detail about how to maintain standards and teaching quality in this period next week. OfS has highlighted slimmed down regulatory requirements for reporting some issues related to teaching and learning including that providers will therefore be required until further notice to report on:
- where they cease or suspend courses without providing equivalent alternative study options
- where they are unable to award qualifications or credit as they had planned.
How are members facilitating practical assessment for courses with learning outcomes that require making, doing or performing?
Members on the call were exploring using practical work completed before the switch to online such as storyboards, sketches and plans, alongside modified assessments exploring what the student would have produced, as the most common model. Other members were asking students to continue to create where possible and produce film and audio submissions of creations, uploading using VLEs, Microsoft teams, Google drives and other similar systems. Members were careful to stress that they had developed specific guides to help students submit digitally, and policies for if/when technology was a challenge for students. They stressed to ensure deadlines were during the teaching day so students could reach out for help, instead of at midnight when staff would be unavailable. Jisc has made much of their online content and support free for all HE and FE providers until 31 July via their website. Their resources include great tips on software and methods to support delivering and assessing online, including for providers of creative, practical, vocational and experiential learning. They have digital resources for training subjects from hairdressing to education and great guides on transforming assessment. There is also a useful website Transforming Assessment running webinars for providers and have example assessments for different subjects including arts, music, education, psychology and others.
Yes. Whilst the pass/fail model isn’t commonly used across the UK HE sector, it is a recognised and acknowledge form of classification for Level 6 qualifications. As long as any move from one system to another is appropriately managed and students and partners are involved with the process then this is ok. Communications to students must manage expectations with this change in classification. QAA has published guidance for pass/fail models in professional courses which can be referred to for information in Annex D.
QAA has highlighted in their latest guidance from 23 March that: “For degree-awarding bodies, the responsibility to maintain standards remains yours. Governing bodies need to be satisfied that academic standards are being achieved no matter what adjustments you need to make to the learning and assessment strategies in light of COVID-19". Providers who have degree awarding bodies must make their own decisions, and those working in partnership should work closely with their partners. The full guidance can be found here. QAA members can also contact their Membership Engagement Manager for further support and attend QAA’s Headline Briefing webinar on Friday 27 March or join their online Quality Clinics.