Disabled Students Allowance Consultation Response September

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24th September 2015
Disabled students in higher education: funding
proposals – open consultation.
Response from the Alliance for Inclusive Education (ALLFIE)
About ALLFIE
The Alliance for Inclusive Education (ALLFIE) is a national campaigning
and information-sharing network led by disabled people. Inclusive
Education is underpinned by the social model of disability principles. The
removal of the organisational, environmental and attitudinal barriers that
prevent disabled students from participating in mainstream education
including higher education. ALLFIE campaigns for all disabled people to
have the human and civil right of access to and to be supported in
mainstream education. For more information please see the ALLFIE
website: www.allfie.org.uk .
The UK is a signatory to the UN Convention on the Rights of Persons
with Disabilities (UNCRPD). Article 24 of the UNCRPD imposes an
obligation, to provide not only mainstream education including the
opportunity to go to university, but also the support required to facilitate
disabled students’ participation. Article 24 outlines best practice, and
adherence to it means that there is proper provision for disabled
students to have the same entitlements and offer of education support
as their non-disabled peers at all levels of study.
Inclusive Education: the role of Disabled Students Allowance (DSA)
Whilst the Government is under an obligation to promote inclusive
education practice there is no guidance on what the guiding principles
should be to guide policy and implementation. A lack of principles based
on inclusive education across Education and Equality legislation and
policy has meant that Government policies aimed at promoting disabled
students’ access to mainstream education has been incoherent and in
many cases goes against good practice. Whilst the Government wants
HE providers to promote inclusive education, there is no guidance for
education providers on how this should happen. A lack of guidance has
resulted in education providers themselves deciding what is or is not
considered as inclusive education practice; inevitably there is no
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consistency or transparency in how education providers meet the needs
of disabled students or in the development of inclusive education
practice.
Timing of Consultation
We note the timing and period of consultation (between July-September
2015) was during the student summer break – when they are not on
campus. Our evidence has been that, because of the timing, University
Student Union Disabled Students’ Officers and staff are unaware that
the BIS DSA reforms consultation is happening. By arranging the
consultation during the summer break the Government has made it clear
it is not interested in student opinions and feedback.
Alliance for Inclusive Education recommendation
After careful consideration of the options set out in the consultation
document, we believe the best option is to retain the current Disabled
Students Allowance arrangements with an increase in the DSA budget.
ALLFIE believes that the DSA reforms must be considered within the
context of the Government’s plan to rebalance the responsibilities
between the State and public bodies for both the funding and provision
of support that disabled students will need to access higher education to
support inclusive education practice. As a result of the Government’s
welfare reforms, including the closure of the Independent Living Fund,
disabled people have faced unprecedented cuts in their social care
provision and welfare benefits. The anecdotal evidence, since the
closure of the Independent Living Fund, is that disabled people are now
facing substantial cuts to their social care provision, inevitably impacting
on those disabled people seeking to participate in higher education. This
is despite Government’s intention that LAs will be able to pick up the
funding to cover social care support.
In terms of HE providers, the evidence so far is that they are also facing
substantial cuts to their budgets, and are very likely to be unable to fund
the support that disabled students require in lieu of a much reduced
DSA. Indeed in the last Government Equality Impact Assessment, HE
providers have already warned that they will not be able to fund the
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support that disabled students require as part of their Equality Act 2010
Reasonable Adjustment duty.
“Some respondents highlighted the perceived unfairness of
‘punishing’ those institutions who had made the greatest efforts to
recruit disabled students.”
“Some respondents also noted that the burden of disability
spending would fall disproportionately on small and specialist
institutions, such as creative arts institutions, which have small
reserves and would not be able to take advantage of economies of
scale when providing for disabled students. Consequently, support
for disabled students may become unevenly-spread, with some
institutions offering more in this area than others.”
The increased financial pressure on HE providers to fund additional
support will inevitably affect admissions tutors’ attitudes when recruiting
disabled students. John Hilsdon, Head of Learning Support and
Wellbeing at Plymouth University, was quoted recently, warning that:
“The financial burden that reforms would put on institutions might
act as a disincentive for some universities when recruiting disabled
students.”
Since the announcement of the DSA reforms, evidence suggests that
disabled students are less likely to consider higher education in the
future.
“More than one in three students with a disability (34%) say they
would definitely not have attended university without DSA support,
while a further 36% are unsure if they would have originally
attended. Less than one in three students with a disability (30%)
would still definitely have decided to go to university without the
support of the DSA.”(RANSDED 2014)
This year York University funded research by the Higher Education
Funding Council found that most students were concerned about
proposed changes to DSA. Students were also concerned that
institutions would view disabled students as a burden, and no longer see
providing SpLD support (specific learning difficulties) as a priority.
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“It’s definitely a concern to me, I see my Disability Support Tutor
every week and I would not be able to function at the level I am
now, and being aided to use technology without that support. I
worry about students who are coming in a few years’ time without
that support.” ( Disabled Student in HE)
We are concerned that we will see a steady decline in numbers of
disabled students accessing higher education as a result of a
combination of DSA reforms and other cuts in disabled people’s
community based support. That decline has already been noticed by HE
teaching staff:
“I have worked with students who have been forced to stop
attending or drop out altogether due to a reduction of support from
Disabled Students Allowance and changes to Independent living
funding.… ” (Disabled University lecturer)
It is clear that disabled students will be significantly affected if the
proposed DSA reforms are implemented. If the reforms are really being
driven by the Government’s desire to shift the balance of responsibility
away from BIS and create greater reliance on HE provider Equality Act
2010 Reasonable Adjustments duties, this will only create greater
inconsistency in NMH (band 1 and 2).
Q1: Do you think a minimum level of reasonable adjustments for all
HE Providers could help ensure a consistent approach to making
reasonable adjustments? If yes, what areas do you think should be
covered? Please state what you think the minimum level for each
area should be.
Yes we agree that a minimum level of reasonable adjustments would
help HE providers understand what they are expected to do in order to
promote inclusive education practice, but this must cover course
admissions, examination and assessment arrangements, course
curricular, teaching and learning practices.
In our opinion if the Government decides that there should be a
minimum level then the Equality Act 2010 would have to be amended so
that adjustments are considered universally rather than on a case-bycase basis. Currently there is no statutory guidance to say what
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adjustments should be considered as ‘reasonable’. So therefore it is for
individual HE Providers to determine for themselves what
accommodations will be considered as ‘reasonable’ for individual
students.
Q2: Do you think there are other mechanisms that could be
introduced to achieve a consistency of reasonable adjustments for
disabled students across all HE Providers? If yes, please describe
them.
We believe that the DSA, as it is currently, provides a very good
mechanism for ensuring that disabled students get the support they
need to participate fully in the HE learning environment regardless of HE
providers’ circumstances. For instance a disabled student needing NMH
Band level 1 or 2 support will receive it regardless of which university
they choose to attend. This is because once a disabled student has had
a DSA application approved, then she/ he will receive that support. In
other words, the funding of NMH follows the student.
BIS needs to ensure that the HEFC funding for disability is not only
protected but is increased for HE Providers with a high proportion of
disabled students. In addition we would recommend that BIS has a
separate fund that can be utilised if HE Providers find themselves in
financial difficulty when funding disabled students’ access arrangements.
Both of these measures would improve the consistency of support that
disabled students will receive.
Q3: Do you have any examples of how it might prove difficult for an
HE provider to make reasonable adjustments because of the nature
of their student population (e.g. if the HE provider has a very large
or small student cohort)? If you have, please explain why this could
be difficult.
We do not have specific examples of how the nature of student
populations will present specific difficulties for HE Providers in complying
with their Equality Act 2010 Reasonable Adjustment duties. However the
Government’s own Equality Impact Assessment on the DSA reforms
highlighted that HE providers specialising in particular subject areas
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(e.g. creative arts) would find it difficult to accommodate disabled
students’ reasonable adjustments.
Those HE providers that have a tradition of welcoming and recruiting
disabled students will also face difficulty in accommodating the range of
reasonable adjustments that would have been funded by DSA. This is
because those HE providers that build a reputation of welcoming a
diversity of students usually attractive disproportionate numbers of
disabled students on the understanding that the HE provider will have a
more positive approach to providing the right levels of support.
HE providers that have traditionally recruited students via the UCAS
clearing system will find it difficult to forward plan, budget and arrange
disabled students’ reasonable adjustments before the beginning of the
academic year because they won’t know the makeup of those students
that have successfully achieved the required grades.
“I went to my university through clearing and I was so worried
about getting the right care and support in place, that I missed out
on valuable social opportunities. In fact, it wasn't until my third and
final year that I actually felt like part of the university community.”
(Disabled student in HE)
If disabled students have DSA, they will be able to transfer that support
over to a different HE provider with minimum impact on individual
disabled students.
Q4: Do you think the Government’s preferred option for nonmedical help changes fulfils the policy rationale of making HE as
accessible as possible, re-balancing support between HE Providers
and DSAs, and improving value for money? If no, please give
details of your reasons.
No. Our preferred alternative option is a) – No change to the current
arrangements.
Disabled students in receipt of DSA are more likely than disabled
students without DSA and non-disabled students to complete their HE
courses (NOA 2007), and disabled students with DSA are more likely
than their disabled peers without DSA to achieve their academic goals
and grades. (ECU 2012) So therefore DSA is an excellent funding
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stream supporting disabled students to complete their course of study
successfully.
DSA funding effectively levels the playing field between disabled and
non-disabled students. Disabled students are able to apply for courses
without having to consider whether or not a particular university will be
able to arrange/afford their support requirements. The availability of DSA
means HE providers can consider all students on their own merits,
without having to think about whether an individual disabled student’s
support package can be ‘reasonably’ funded.
“Unfortunately the barriers associated with accessing higher
education are numerous and complex and whilst DSA does not
overcome all of these barriers, it does make higher education feel
like a more realistic option for disabled people by at least
attempting to even out the playing field.” (Disabled student in HE)
On this basis and under the current DSA arrangements, two disabled
students with the same impairments and support needs attending
different universities reading the same subject are very likely to receive a
similar level of grant. The benefits of DSA cannot be underestimated for
achieving equality of access to higher education for disabled students.
“I am currently a PhD student in receipt of Disabled Students
Allowance. I have had Disabled Students Allowance throughout
my university career and without its existence it is unlikely that I
would have had the confidence to attend university at all. Due to
my impairments I have high educational support needs. I have
relied on DSA throughout my degrees to give me access to my
courses. I have needed people to take notes, people to scribe for
me, one-to-one tuition and people to offer library support
throughout all of my degrees. I have also required assistive
technology, dictaphones and laptops.” (Disabled student)
One of the most important aspects of DSA support is that it is tailored to
meet the individual requirements of each disabled student. DSA support
is funded by a central budget, which means that funding follows the
student wherever they choose to attend university.
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Integration of funding streams
The Government has been promoting greater personalisation where
care and support is tailored to fit around the disabled person’s individual
needs. Personalisation or person-centred planning is at the centre of the
various grants disabled people are eligible for - Direct Payments for
Special Education Needs, Education Health and Care Plans, Access to
Work and the current Disabled Students Allowance allow disabled
people to manage their assistance in a much more personalised manner
than would be possible only through traditional service provision and
agency contracts.
One of the key changes in the Government’s recent reforms of Special
Education Needs has been extending direct payments (personal
budgets) to include SEND provision - thereby offering disabled
pupils/students and their families greater choice and control over the
support they receive from education, health, social care. For instance a
disabled student at school can employ and use the same PAs (personal
assistants/support workers) both within and outside education settings.
By combining the funding this student, below, has been able to employ
the same staff to work with him throughout his academic, employment
and leisure activities.
'My ILF and DSA ensured that I was on an equal level with my
non-disabled peers. My access needs were met, I had specialist
software and academic tools that meant I was in control of my
studying and I was able to employ a Personal Assistant to provide
personal care and academic support when I wanted it, how I
wanted it. All of this meant I felt valued and respected by my peers
and lecturers. I wouldn't be where I am today without ILF and
DSA.' (Disabled student)
If DSA is removed or significantly reduced, we expect HE providers will
opt for providing the NMH themselves which would not always be
compatible with existing arrangements that disabled students have in
place. With the planned changes to DSA, disabled students are likely to
have to rely on different workers (employed directly by the HE provider),
to the ones they are used to working with on a day-to-day basis as HE
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providers will want to go for a general pool of NMH level 1 & 2 support
workers which would be considered to be more cost effective.
“At Bristol, I employed my own Support Workers/PAs direct, and
then claimed for their hours on my DSA. SFE claim this was never
an official arrangement and now say I must work with Support
Workers supplied by the university (i.e. SFE 'recognised
suppliers'). Having employed my own PAs for the past 25 years
under Direct Payments, there's no way anyone's going to tell me
who's going to assist me with personal stuff!” (Disabled student)
“I received DSA for my 4 year university course, finishing in 2009. I
initially started by going through my education support office to get
my assistance, however I realised that if I took over the
responsibility of paying then, by eliminating the admin charges, I
would be able to pay for more hours. Once I had taken over the
responsibility, the quality of my support improved, as the recruiting
and advertising I did was specific to my requirements.” (Disabled
student)
When using DSA, disabled students have flexibility of whether or not to
use university disability services.
“When completing a Graduate Diploma in Law, my DSA was used
to fund the University’s disability services weekly study sessions
on campus site at a time that was convenient for me. However
whilst the service worked well with the university and level of
study, it was very different when I completed a MA Healthcare Law
and Practice course. The study skills support was at an
inconvenient time on a different campus to the one I was attending
to complete the course. I was fortunate as my LA (before SLE)
were happy for me to employ my own study skills support worker
that will work more flexibility around a more intellectually
demanding course.” (Disabled student)
We anticipate with universities facing substantial cuts to their budgets
that they will be less likely to want to provide disabled students with the
funding to employ their own NMHs.
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Q5: Do you think any of the alternative options in paragraph 58 for
non-medical help provision could deliver the support required and
meet the need to make HE as accessible as possible, re-balance
support between HE Providers and DSAs, and improve value for
money? If yes which one(s)? Please give details, explaining how
the proposal takes account of the legal duty imposed on HE
Providers.
We do not have sufficient information and time to consider alternative
proposals suggested by Government.
Q6: Do you have an alternative proposal for non-medical help
provision? If yes please give details, explaining how your proposal
takes account of the legal duty imposed on HE Providers, and
meets the policy rationale (i.e. the need to make HE as accessible
as possible, balance support between HE Providers and DSAs, and
improve value for money)
We have not had sufficient time to give detailed alternative proposals.
However, we can provide a few broad suggestions for how we think DSA
can be improved for disabled students.
We would welcome the opportunity to discuss further improvements to
the DSA arrangements with BIS.
Re-consider the Bulk Purchasing equipment
The bulk purchasing of computers and peripherals can sometimes mean
that there is limited flexibility in providing equipment that best suits
disabled student’s needs. Often buying equipment that best meets
students’ individual needs can save money, in the long run, as the
example below highlights:
“Frustratingly from me as somebody who is returning to education
some assistive technology that I need would cost £250. As the
piece of equipment has not been funded before, DSA will not cover
the costs. Instead DSA have funded £500 worth of assistive
technology, which is not well suited to my needs in order to try and
do what this one piece of technology does.” (Disabled student)
Opportunities to try out solutions
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For many disabled students, DSA is the first time they have been
provided with human/financial assistance with their studies. Currently
DSA does not always provide sufficient flexibility to allow disabled
students to try out various learning strategies and equipment before
making any commitment. What will work for one disabled student will not
necessarily work for another student with similar impairments/health
conditions. So ALLFIE would like HE Providers, the DSA and disabled
students working collaboratively, early on, to identify a range of solutions
over a given period of time, thus allowing students to test out different
approaches and identify which approach works best and enable the
disabled student to fully participate in learning.
Increase Flexibility
Historically the DSA provided real flexibility for disabled students,
particularly those who received direct payments for social care. However
more recently disabled students have noted a decline in that flexibility:
“At Bristol, I employed my own Support Workers/PAs direct, and
then claimed for their hours on my DSA. SFE claim this was never
an official arrangement and now say I must work with Support
Workers supplied by the university (i.e. SFE 'recognised
suppliers'). Having employed my own PAs for the past 25 years
under Direct Payments, there's no way anyone's going to tell me
who's going to assist me with personal stuff!” (Disabled student)
Q7: In NMH Band One categories a - e and g on pages18-20 are
there any circumstances where the primary responsibility for
provision should not sit with the HE provider? If yes, please give
full details and explain your reasoning.
From the work we do with disabled students it is clear that there remains
a huge inconsistency of approach to providing support to disabled
students – this will only get worse as different HE providers determine
what they consider to be ‘reasonable’.
For example there is a danger that two disabled students with similar
physical impairments studying the same science-based course at
different universities could be treated differently in respect of whether or
not note taking and/or whether science lab and library assistance is
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required, what the hours of support should be and whether it should
cover all aspects of student life. By retaining levels 1-2 under the DSA
funding, disabled students will know clearly if they meet the eligibility
criteria, they would then receive the necessary NMH level 1 and 2
support regardless of university or course of study choice.
Q8: In NMH Band One category f on page 19 are there any
circumstances where the primary responsibility for provision
should move to the HE provider? If yes, please give full details, and
explain your reasoning.
Unable to comment
Q9: In NMH Band Two categories a – c on pages20-21 are there any
circumstances where the primary responsibility for provision
should not sit with the HE provider? If yes, please give full details
and explain your reasoning.
Unable to comment
Q10: In NMH Band Three category c on page 22 are there any
circumstances where the primary responsibility for provision
should not sit with the HE provider? If yes, please give full details
and explain your reasoning.
Unable to comment
Q11In NMH Band Three categories a, b, and d are there any
circumstances where the primary responsibility for provision
should move to the responsibility of the HE provider?
Unable to comment
Q12: In NMH Band Four categories a - e on pages 24-25 are there
any circumstances where the primary responsibility for provision
should move to the HE provider? If yes, please give full details and
explain your reasoning.
Unable to comment
Q13 Do you have detailed edits or comments on the draft NMH
guidance? These can be provided below.
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We have not had the time to look at the draft NMH guidance.
Q14: Where accommodation is owned and managed by the
institution or its agent, do you agree that the additional costs of
providing specialist accommodation for disabled students should
not be passed on to the student? If not, please explain your
reasons?
Yes we agree that the additional costs should not be passed to disabled
students. In addition disabled students should not be charged for
additional rooms if they require overnight support from personal
assistants.
Q15: What other approach would you favour for funding specialist
accommodation? Please explain why.
If new housing stock is being built, then there must be a requirement for
the building to be fully accessible for all, based on inclusive design
principles. All student facilities, including bed/study rooms need to be
fully accessible for a range of disabled students.
If all student accommodation incorporates inclusive design features then
there will be less need for the DSA to cover specialist accommodation
for disabled students.
Q16: Do you agree that the primary source of hard copy materials
should be through an institution’s library services to remove the
need for individual printers, scanners and hard copy materials? If
not, why? What alternatives do you suggest?
We agree that HE Providers should do more to make library services
much more inclusive of disabled students. However whilst HE Providers
must make every effort to ensure their library services are fully
accessible and inclusive, we do believe that some disabled students are
likely to still require individual IT equipment, for example:
“Because I have an impairment that affects my mobility as well as
a specific learning disability hard copies of books are not
accessible to me, meaning that in order to be able to access the
books’ content, I require the book to be scanned so that I can then
put it through my assistive technology. Whilst my university provide
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book collecting services they do not provide scanning copy
services. My mobility impairment means that I am unable to use a
photocopier or scanner (that's assuming I can get anywhere near
them) independently in all of the University's libraries. Therefore I
use my DSA allowance to pay for a library assistant to do the
scanning for me. Whilst electronic books are on the increase, the
way in which my university subscribes to those services means
that they are of limited use to me as the electronic format is not
compatible with my assistive technology and any notes or
annotations are lost when the loan expires. Whilst my university
library and IT support try and assist me with the complications of
assistive technology and e-books, neither side have enough
knowledge of assistive technology or my access requirements to
find solutions without the additional support I receive from assistive
technology experts through my disabled students allowance.”
(Disabled student)
In order to access material, disabled students need an approach that
has enough flexibility to deal with their personal situation, such as
fluctuating health conditions or mental health conditions. These may
mean that they find it difficult to use the library facilities, or that they are
not well enough to use the library. An alternative might be that the library
could offer a loan scheme for equipment such as printers/scanners to
those disabled students, but this inevitably has a cost implication to the
HE provider. The key is flexibility which is at least available under the
current arrangements for the DSA scheme.
Q17: Do you agree with this approach to the funding of standard
computer peripherals? If not, why? What alternatives do you
suggest?
It is important that DSA covers the costs for computer and peripheral
equipment if disabled students cannot access or reasonably use the IT
facilities on campus. Unless all computer stations include assistive
technology facilities, it is essential that DSA covers disabled students’
computer-related costs so that they are placed on an equal footing with
their non-disabled peers.
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Q18: Do you agree with this approach to funding items referred to
as ‘the bundle’? If not, why? What alternatives do you suggest?
See answer to question 17.
Q19: Do you agree with this approach to funding audio capture
equipment? If not, why? What alternatives do you suggest?
Whilst many disabled students will find mobile phones and/or apps offer
sufficient quality to record lectures and workshops, in this way providing
accessibility, this will not be the case for all.
DSA should provide sufficient flexibility for disabled students to have the
best suited equipment to record their lectures and workshops and
undertake interviews.
Q19: Do you agree with this approach to funding audio capture
equipment? If not, why? What alternatives do you suggest?
We do not see any problem with this general approach. However, as we
have said in our answer to Q19 whilst many disabled students will find
mobile phones and apps fully accessible and of sufficient quality to
record lectures and workshops it will not be the case for all. DSA should
provide sufficient flexibility so that disabled students have the equipment
they can use in order to record their lectures and workshops and
undertake interviews.
Q20: Are there circumstances where the primary responsibility for
providing an individual item of IT related equipment, for example a
printer, scanner, DVR etc. should fall to a student’s HE provider? If
yes, which items of equipment would fall into this category? If yes
or no, please give reasons for your answer.
Unable to comment
Q21: We have described how we think HE Providers can best fulfil
their obligation to supply reasonable adjustments for disabled
students. Are there other ways in which they could do so? If yes,
please describe them.
Although there remain some inconsistencies, HE providers currently
have ‘reasonable adjustment’ duties in respect of their admissions
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processes, conditional offers, assessment and examination
assessments and participation in student extra-curricular activities. A
clearer mechanism for ensuring that HE providers meet these
fundamental obligations would be useful.
We believe the ‘balance of responsibilities’ between DSA and HE
providers is about right whereby the provider makes ‘reasonable
adjustments’ for disabled students for course-related activities. As these
‘reasonable adjustments’ do not generally involve questions of money,
then, we find from the work we do with disabled students, that decisions
are less likely to be affected by financial considerations, giving rise to
conflicts of interest.
Q22: How should any changes introduced be monitored and
evaluated to ensure students are receiving a consistent service and
are not being disadvantaged?
Currently there are few opportunities to feedback on the quality of
support that disabled students receive, other than via the Disabled
Students Allowance Quality Assurance Group (DSA-QAG) which is not
widely publicised. It is unclear whether the DSA-QAG has any legal
powers, similar to those of an OFFA (Office for Fair Access) or the
Ombudsman. Therefore we want to see more comprehensive and
transparent monitoring arrangements for not only the quality of DSA, but
also how HE providers are complying with their ‘reasonable adjustment’
duties.
Q23: Are there any additional safeguards for students that should
be considered to ensure that they receive the support necessary? If
yes, please state what you think they should be.
We can see the rationale for allowing disabled students to be able to
appeal against the HE provider’s decision making as it relates to making
‘reasonable adjustments’ or not, thus avoiding a disability discrimination
case. However, we believe disabled students will face enormous
bureaucracy and time consuming processes should they choose to
challenge their HE provider. We anticipate that there will be a lot of
‘buck- passing’ between the HE provider and SLE regarding who is
responsible for funding and arranging the support under NMH bands 1
and 2. It is unclear what powers of enforcement will be in place if SLE
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determines that the HE provider should provide the disabled student with
NMH under their Equality Act 2010 ‘reasonable adjustment’ duties.
Q24: Some students may not be able to identify their final choice of
HE provider until the clearing process. Do you think that any
specific arrangements need to be put in place as part of clearing? If
yes, what are they and why do you think they should be put in
place?
Like many students, disabled students have to wait until after their A
level results before accepting first, second or clearing choice HE
provider offers. For this reason individual HE providers cannot know
what their student intake will be early enough to plan for the financial
implications.
“I went to my university through clearing and I was so worried
about getting the right care and support in place, that I missed out
on valuable social opportunities. In fact, it wasn't until my third and
final year that I actually felt like part of the university community.”
(VInvolve Project - Muscular Dystrophy Society)
This situation would be avoided if disabled students have a DSA
package agreed beforehand which they can use after accepting their
first, second or a clearance HE provider offer.
Q25: Do you have any relevant additional information that you
would like to be considered as part of the ongoing Equality
Analysis? If yes, please provide
We remain concerned that with the proposed reforms, disabled students
will be facing greater financial costs than their non-disabled peers when
accessing higher education. Many disabled students will be required to
finance the evidence they need to demonstrate eligibility for DSA. For
instance an educational psychologist’s report to confirm a disabled
student’s specific learning difficulties diagnosis over the age of 16 years
of age can run into hundreds of pounds. Similarly disabled students may
be required to pay for medical reports if NHS doctors refuse to provide
evidence for a DSA claim.
ALLFIE continues to contest the £200 contribution that disabled students
will be expected to make towards a DSA assessed computer on
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principle because this is yet another cost that disabled students will have
to meet that is not relevant to nondisabled students.
There needs to be greater equality analysis on the impact of additional
costs that disabled students will incur as set out above. The Equality
Impact Assessment must cover the impact that Welfare Reform
changes, ILF closure, benefits reductions and education policies will
have on the ability of disabled people to access higher education
options.
There is a need to consider the cumulative impact that the Government’s
welfare and social care cuts are having on disabled individuals who want
to participate in higher education. Insufficient social care support or
income will mean that disabled individuals may choose not to apply for a
university place. For this reason the new Equality Impact Assessment
must not only consider the impact of DSA reforms but also the other
policy agenda that is stripping disabled individuals of the support they
require to even consider the possibility of accessing higher education.
For example, this disabled student has used her Student Loan to cover
the cost of care due to the closure of the Independent Living Fund.
However, this arrangement will not be an adequate solution to the social
care crisis.
“The absence of the ILF also meant not having enough money to
pay for the amount of care that I at needed at university…
Eventually I had to use my student loan to pay for the other half,
when it should have been used for other expenses. I believe that
by removing the ILF it is preventing disabled people from living
fully independent lives. We have the right to have the same quality
of life as our non–disabled peers; we just need extra help to do
this, which is what the ILF can give us.” (Disabled student)
Substantial cuts to social care packages, loss of Personal Independence
Payments and reduction of benefits all have a cumulative and damaging
impact on disabled people’s ability to thrive, have choice and control in
their lives and participate in education.
NAO 2007 Staying the course: The retention of students in higher
education
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http://www.hefce.ac.uk/media/HEFCE,2014/Content/Working,with,HE,
Providers/Equality,and,diversity/Objectives,information,and,data/HE%20
Student%20Equalities%20tables%20by%20Disability%202013-14.pdf
For more information please contact:
Simone Aspis – simone.aspis@allfie.org.uk
Tara Flood – tara.flood@allfie.org.uk
Alliance for Inclusive Education 336 Brixton Road, London, SW9 7AA
Tel: 020 7737 6030 Website: www.allfie.org.uk
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