SPA response to the QIR consultation
April 2012
Recommendation 1
The Qualifications Information Review recommends the development of UCAS Qualification
Information Profiles and an associated database designed to give admissions tutors the
information they need about applicants’ qualifications.
1.
To what extent do you agree, in principle, with the recommendation to develop
Qualification Information Profiles and associated database?
Agree
SPA supports the development of Qualification Information Profiles and an associated database
along the lines outlined as it would help HEIs significantly if the information they needed about UK
qualifications to aid them in making admissions decisions was available together, in one place. The
QIPs are a useful move forward if they include all level 3 qualifications, but these are not all the
qualifications that are used for entry to HE. They will not include:
 level 4/5 qualifications commonly used as routes to degree – e.g. foundation courses,
HNDs, DipHE;
 the majority of international qualifications.
SPA believes the standardisation of some qualifications information will be welcomed by HEIs.
However, information about some qualifications, such as Access Diploma Programmes, may fit
less easily into QIPs and UCAS will need to ensure there is a mechanism by which this information
can be made available to HEIs. It is also noted that the database will be freely available on the
UCAS website to member institutions and those outwith membership, as well as to applicants,
teachers, advisors, parents, other organisations and agencies etc. SPA notes the proposal in
Section 14 Implementation and resourcing, that UCAS intends to meet the cost of developing,
delivering and running the new service. However if the cost of implementing and delivering the new
service cannot be met from existing UCAS resources then the additional costs could be covered by
a small increase in the annual capitation fee paid by UCAS members. There could be questions of
fairness if the cost makes it prohibitive for some institutions, and institutions which may not wish to
use it may also wish to opt out of paying for it.
2.
What would be the impact of this recommendation on you/your organisation?
SPA receives enquiries from HEIs and other sector stakeholders about qualifications, particularly
about qualifications which are not on the UCAS Tariff, on a regular basis, with regard to good
practice and other issues. This recommendation should lead to more information being provided
about a greater number of qualifications, particularly new qualifications and those not currently on
the UCAS Tariff, if it does not then enquiries to SPA are likely to continue and possibly increase.
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3.
To what extent do you agree that this recommendation supports fairness, transparency
and efficiency in HE admissions?
Strongly
agree
Agree
Neither agree
nor disagree
Disagree
Strongly
disagree
x
Fairness
x
Transparency
x
Efficiency
SPA agrees in principle with the development of QIPs and recognises that this is a positive step
towards supporting HEIs and providing efficiencies through shared services. However, there won’t
be QIPs for all qualifications e.g. many vocational qualifications and those which make up part of
apprenticeships (at least at first) and this could lead to some applicants not being assessed as fairly
i.e. the perception that if there isn’t a QIP the qualification doesn’t have utility for progression to HE
is likely to persist (as it does currently if a qualification isn’t on the Tariff). Some QIPs are likely to
have gaps as vocational qualifications won’t have been demand rated, again this could lead to
disadvantage for applicants with certain qualifications. QIPs should aid transparency but we are not
clear as to any evidence that they would lead to greater efficiency in HE admissions.
4.
A number of stakeholders have identified additional information that they would value
about qualifications. To what extent do you agree that the following information should
be included, alongside judgements relating to academic demand?
Strongly
agree
Agree
Personal skills (e.g. team
working and self management)
Vocationally related skills and
knowledge
Other, please specify below
5.
Neither agree
nor disagree
Disagree
Strongly
disagree
x
x
x
Please use this space to explain your views in more detail:
The development of team working and self management skills are very relevant for most HE
courses. However the process by which this can be delivered in a consistent way across all
qualifications needs to be made clear. HEIs would need to ensure fairness and consistency in
using this information as part of admissions decision-making. If this aspect of the proposals is
agreed by the HE sector, HEIs will have a view about who will make the value judgements on the
extent of these personal skills in the QIPs.
There will be specific vocationally related skills and knowledge the development of which will be
very relevant and in some cases essential for entry to some HE courses. Consideration must be
given in relation to who decides/how it is decided what constitutes ‘vocationally related’ and the
way in which this definition can be consistently applied.
Other issues:
 information about assessment, about the balance between internal and external
assessment, coursework and examinations and amount of independent learning required;
 information about coverage of Study Skills;
 breakdown of optional and mandatory units e.g. for Access Diploma Programmes;
 qualifications resit policies e.g. whether allowed and number of times students are able to
resit;
 whether predicted grades are likely to be available (for some Access Diploma Programmes
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this is unlikely as students will have been studying for a very short time when they make
their UCAS applications);
 content level(s) – this is particularly important in qualifications where content levels are
mixed;
 the purpose of the qualification i.e. the learning outcomes and skills which students are
expected to develop and achieve;
 measure of practical and creative demand for qualifications where this is relevant.
6. Please share any views you have on how this information might be collated and
presented.
In addition to the independent criteria identified in section 9.3, the new qualifications advisory
group could also use and expand upon the use of the Tariff domain scoring methodology to ensure
skills other than those highlighted in section 9.2 can also be assessed as adding value to a
qualification, in terms of it having utility for progression to HE. This information should form part of
the QIP and should not be treated differently to the other information which is being assessed, if
we are trying to achieve a system which provides comprehensive and complete qualifications
information.
7.
To what extent do you agree that profiles of apprenticeships and Access to HE courses
should be made available to HE, alongside level 3 UK and selected international
qualifications?
Strongly
agree
Agree
Apprenticeships
x
Access to HE courses
x
Neither agree
nor disagree
Disagree
Strongly
disagree
SPA agrees that this should be part of the provision of comprehensive qualifications information, to
aid fair admissions and equal treatment of all HE applicants with a variety of qualifications.
8.
Some stakeholders have suggested that they would like UCAS to provide further
information about other courses/qualifications/tests, such as level 2 qualifications
and/or admissions tests, alongside that proposed for level 3 qualifications. To what
extent do you agree that this additional information should be made available?
Strongly value
Value
Level 2 qualifications
x
Admissions tests
x
Other, please specify below
x
9.
Neither value
nor not value
Do not value
Strongly do
not value
Please use this space to explain your views in more detail:
Consideration of some level 2 qualifications forms an integral part of many HEIs’ admissions
decision-making processes. As such, it would add to the comprehensiveness and completeness of
the proposed qualifications information system, to ensure HEIs have access to this information.
Since 2007 SPA has analysed the data on the number and use of admissions tests by HEIs in the
UK, and has published comprehensive information about this to the pre-HE and HE sectors. From
2012 UCAS will take over the collection of admissions tests information and in 2012 SPA will
produce statistics and commentary about the numbers of tests in use and how they are used in the
admissions decision making-process. This information will be published on the SPA and UCAS
websites and a link to this on each QIP might be helpful to HEIs.
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10. Please indicate whether you would favour a September 2013 or January 2014 launch of
the Qualification Information Profiles and associated database and why you give this
preference.
Favour September 2013.
SPA would suggest that this new service should start at the beginning of an admissions cycle, so
of the choices offered, September 2013. However, SPA would question whether transferring all
relevant qualifications information into the QIP format is achievable by September 2013? Sufficient
time must be allowed to ensure as many qualifications as possible are covered when the new
system is launched. A mid-cycle launch could be unfavourable as this could lead to mid-cycle
changes to qualifications accepted and changes to entrance requirements, this in turn could lead to
a risk of unequal treatment of applicants. The lead-in time needed by HEIs must also be
considered. If HEIs are to use QIPs to influence entry requirements and offer-making, they should
have access to QIP information at least 18 months beforehand, to ensure it can be included in
prospectus information.
11. Please use the space below to outline what transition arrangements, if any, you think
may be necessary to ensure that future applicants are not unfairly disadvantaged by
implementation timing.
A launch at the start of an admissions cycle is important, to ensure that applicants at all stages of a
cycle are treated equally in terms of the qualifications information which is available to their chosen
HEIs. Making additional information available about qualifications part-way through an admissions
cycle could lead to inequities and unfairness to some applicants i.e. if insufficient information was
available about a qualification between September and December to enable offers to be made, but
the launch of the new system in for example, January, makes more information available and HEIs
can see a qualification has utility for progression to HE, offers may be able to be made at this
stage. If the new system is launched in January, HEIs would need clear guidance to ensure this
new information is made available to enable them to prepare for the admissions cycle to come, not
the one which is underway.
12. Please use the space below to outline what communications and guidance you feel
would be necessary to support implementation of this recommendation.
Both the pre-HE and HE sectors would need clear guidance:



about when the new system would start;
the purpose of QIPs, for applicants and advisors in particular, to ensure they don’t
misunderstand what they are intended for;
to understand and correctly interpret QIPs.
HEIs would also need guidance about where to find information for qualifications for which there
isn’t a QIP, or where the information in a QIP is incomplete.
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Recommendation 2
The Qualifications Information Review recommends that HEIs consider the gradual
withdrawal of the use of UCAS Tariff points for setting entry requirements and for offer
making, coupled with the promotion of the greater use of qualifications and grades for
setting entry requirements and making admissions offers and decisions. This would need
to be accompanied by an extensive communication programme to support applicants and
advisers. UCAS would commit to maintaining the existing UCAS Tariff for an agreed period
of time, but would not evaluate new qualifications for inclusion after an agreed deadline.
1. To what extent do you agree, in principle, with the recommendation for the gradual
withdrawal of UCAS Tariff points for setting entry requirements and for offer-making,
coupled with the promotion of grade-based entry requirements and offer-making?
Neither agree nor disagree.
Institutions have a choice about which offer-making method to use, and UCAS as a shared service
should provide a system which supports more than one method. If the evidence was forthcoming
for this recommendation then it might be possible to consider agreeing with it. SPA believes that
some institutions may perceive this recommendation to encroach upon institutional autonomy. One
risk of this approach could be that HEIs develop their own tariff-type score, which would be a very
worrying development and could lead to increased inconsistency across the sector. One strength
of a Tariff-based entry requirement is that it covers a range of acceptable grades and applicants
taking a mixture of qualifications. HEFCE has made it clear in its consultation on 2013 SNCs that it
has no plans to consider students taking a mixture of qualifications e.g. A levels and BTECs;
Advanced Diploma; Welsh Baccalaureate, in its equivalences for SNC exemption. If there is no
easy way to represent mixed offerings there is an even greater risk than before that some English
HEIs will overlook them. Some HEIs may struggle to express entry requirements in a transparent
way without the flexibility of the current system which enables them to give applicants some leeway. There could also be resource implications for some HEIs in expressing offers in this way,
particularly at Confirmation, when it will be more time-consuming to analyse results against gradebased offers.
2. What would be the impact of this recommendation on you/your organisation?
This recommendation could have a significant impact on SPA if those HEIs currently using the
UCAS Tariff for offer-making purposes have to change to a grade-based offer-making system, or
choose to develop their own separate tariffs. Staff development will be required in HEIs and SPA’s
good practice guidance in offer-making will need to be updated to reflect this significant change.
3. To what extent do you agree that this recommendation supports fairness, transparency
and efficiency in HE admissions?
Strongly
agree
Agree
Neither agree
nor disagree
Disagree
Strongly
disagree
x
Fairness
x
Transparency
x
Efficiency
SPA does not believe that ‘grade-based entry requirements and offers are more transparent to
learners and their advisors and help to reinforce the importance of qualifications relevance to
specific courses of study’, as stated in section 8.1. If there was evidence to support this SPA would
be very keen to see it. However, we think it is a generalisation to suggest that all grade-based
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entry requirements and offers are more transparent, some might be but not necessarily all. What
about, for example, offers which are based on a range of grades?
4. What are your views on the proposed timing of the withdrawal of the use of UCAS Tariff
points so that grade-based entry requirements are encouraged for all courses starting in
2015 (set by HEIs in 2013)?
SPA does not support the withdrawal of the use of UCAS Tariff points for offer-making, as outlined
in this recommendation because nothing is proposed to replace it, for those HEIs which currently
make full use of it for offer-making.
5. If agreed, we plan to introduce Qualification Information Profiles from September 2013.
During the transition phase, there will be the need for the Tariff to run at the same time
as this new system. For how long should UCAS maintain the UCAS Tariff after the
introduction of the Qualification Information Profiles?
We think QIPs should be introduced from September 2013 for at least all qualifications which are
currently on the UCAS Tariff.
6. From when should we cease to evaluate new qualifications for inclusion in the Tariff?
If recommendation 3 is accepted by the sector, the qualifications advisory group as outlined in
point 9.5 could start to evaluate new qualifications. The review proposes a different use for this
group i.e. that it should agree a rating scale based on the criteria identified in point 9.2 and hence
identify qualifications of equivalent levels of demand for HE admissions purposes. SPA suggests
that this group should respond to sector demand i.e. if demand for a single score for offer-making
purposes is identified in the QIR responses; this group should assume responsibility for that task.
7. Please use the space below to outline what actions UCAS could take to support
you/your organisation during any transition from the use of Tariff points in admissions
to a qualifications and grade-based model.
SPA would wish to work with UCAS to understand the implications of the changes on HEIs’
admissions practices to enable SPA to support HEIs through the development of good practice
guidance in making this transition, if this proposal is accepted.
8. Please use the space below to outline what communications and guidance you feel
would be necessary to support implementation of this recommendation.
Some HEIs would need to undergo significant in-house staff development to move from a Tariffbased offer-making system to a grade-based one. Many HEIs have large standard offer libraries
within their admissions software which would need substantial rewriting. Significant lead-in time
would be needed to prepare, although if there is a transition period where both versions exist, tight
controls would be needed to avoid ‘old-style’ offers being used by mistake, particularly within
devolved areas. UCAS may therefore need to devote additional resources to customer services to
aid applicant interpretation of offers. Advice on how to maintain comparability in offer analysis
across years would be needed, so that HEIs (and external researchers) can accurately compare
between years using the Tariff and any new years not using it. Such advice should extend to
league table providers to avoid any extreme fluctuation. Pre-HE sector representatives,
prospective applicants and their advisors would need clear communications about timeline and
changes to systems. Some students may research their HE choices over a couple of years and
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there would therefore need to be very clear guidance to help them understand any changes during
this period, to avoid any confusion.
9. Please use this space below to add any further comments you have about this
recommendation.
The significance and impact of this change, if it is accepted by the HE sector, should not be
underestimated.
Recommendation 3
The Qualifications Information Review recommends the development of a rigorous means
of comparing ‘demand’ across different qualifications, underpinned by independent criteria
and validated by HE, to support HE admissions decision-making.
1. To what extent do you agree, in principle, with the recommendation for the development
of a means of comparing ‘demand’ across different qualifications, underpinned by
criteria and ratings validated by HE?
Agree
SPA agrees in principle that there needs to be a mechanism for the development of a means of
comparing ‘demand’ across different qualifications, underpinned by criteria and ratings validated by
HE. However, we have concerns that the majority of vocational qualifications will continue to be
excluded in any demand rating. We had anticipated that the QIR would provide an opportunity for a
real step forward with the development of a new methodology in terms of the inclusion of more
vocational qualifications to aid a broader range of potential students in their application to HE
whether they be to HE in FE, university and college, part-time or full-time etc. This part of the
proposal doesn’t aid transparency or fairness as these are likely to be the very qualifications where
not all of the QIP fields will be populated. If this proposal is accepted, the definition of ‘academic
demand’ must be jointly agreed by HEIs, schools and colleges to ensure a common understanding
of the rationale underpinning this methodology and engagement from the education sector as
whole.
2. What would be in the impact of this recommendation on you/your organisation?
This might mean there is a need for SPA to do more work on good practice round vocational
qualifications progression to compensate for and explain the lack of their inclusion in the demandrating process.
3. To what extent do you agree that this recommendation supports fairness, transparency
and efficiency in HE admissions?
Strongly
agree
Agree
Neither agree
nor disagree
Disagree
Fairness
x
Transparency
x
Efficiency
x
Strongly
disagree
SPA has serious concerns about this aspect of the recommendations and is unable to agree with
the proposal that if an applicant looks at UCAS Course Finder but isn’t taking A levels they will
have to refer to ‘the equivalences outlined in the UCAS scale’. UCAS data in 2011 demonstrated
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that more than 50% of applicants apply with qualifications other than A levels. This would be a
really retrograde step, as SPA’s work around transparency in offer-making and entry requirement
statements is all about providing specific requirements for all qualifications, not just focussing on A
levels. This approach wouldn’t be at all transparent and would lead to immense confusion as it
would be almost impossible for applicants to interpret effectively (and how would HEIs know that
applicants’ interpretations were accurate)? Even more worrying is that applicants and/or their
advisors may think they have understood correctly and therefore may make ill-advised
applications. Effective IAG is critical to the success of this, and this particularly affects applicants
from less-privileged backgrounds and those not taking A levels who are less likely to have access
to such support.
This aspect of the proposals does not help the sector to make progress with the vocational
progression to HE agenda. How will HEIs express their acceptance of APEL, APL, APCL and RPL
and how will they ensure applicants’ interpretations of these statements are appropriate? Allowing
applicants to make their own interpretations may lead to some HEIs narrowing their acceptance of
some qualifications and to a narrowing of specific entry requirements, to minimise the potential for
confusion or mis-interpretation. The QIR should also take into account the changes to the
Connexions service in England and the fact that there will be limited IAG available for some HE
applicants. SPA would be keen to see the evidence to support point 9.16 that ‘the establishment of
equivalences based on an academic demand scale would bring a new transparency to qualification
comparisons’ and we would question whether this is actually the case. We think there is a real risk
to this part of the proposal, in that the new grade equivalences would be open to a much greater
degree of interpretation than the current Tariff points system. Because of the concerns expressed
above, it is SPA’s view that we are unable to agree with the judgement of the Review that the
proposals support fair and transparent admissions.
4. Please use the space below to share any comments you have on the proposed academic
demand criteria outlined in the consultation document.
The proposed process to evaluate ‘academic demand’ appears very similar to the current Tariff
methodology, without the additional and valuable domain scoring aspect of qualifications
assessment. SPA is unsure what added value this proposed new process provides.
5. Please use the space below to share any comments you have on the role of the
qualification advisory group, as outlined in the consultation document.
There is a lack of clarity around how the academic demand of qualifications will be ascertained
through this group and more information is needed about how onerous this might be to HE subject
and qualifications experts involved and how this will be resourced. The review doesn’t seem to
acknowledge the strengths of the current system, or try to build on the aspects of it which work
well. It would be helpful to outline how this recommendation of a qualifications advisory group is an
improvement on the existing Tariff Expert Groups. Is there evidence to demonstrate that it will be
any more cost-effective than the current process or are the costs just being shifted from Awarding
Organisations to HEIs? Has a cost-benefit analysis comparing this to the current process been
conducted?
6. Please use the space below to outline what communications and guidance you feel
would be necessary to support implementation of this recommendation.
If the HE sector supports this proposal, it would need to be made clear to them how onerous this
would be in terms of their time. Is it the proposal that members of the qualifications advisory group
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would be drawn from across the sector as they are currently for the Tariff Advisory Group and if so,
how often would the group need to meet? How would members be recruited to ensure a wide
range of HEIs and view-points are represented?
Recommendation 4
The Qualifications Information Review recommends the development of a simple
qualifications metric for HE management information in conjunction with HESA and HEFCE,
SFC, HEFCW and DELNI and following agreement on the UCAS demand criteria and rating
scale.
1. To what extent do you agree, in principle, with the recommendation to develop a simple
qualifications metric for HE management information purposes?
Neither agree nor disagree.
This appears in essence, to be the grade equivalences table with additional columns i.e. Uniform
scale and Standardised demand scale. SPA thinks there is a real risk with this aspect of the
proposals in that of some HEIs which may wish to continue making points-based offers, a few may
well consider manipulating the scores in this table to allow them to do this, if they are not given a
choice in their offer-making methodology. If the work is being undertaken to develop the metric
anyway, why not allow those HEIs which wish to, to also make legitimate use of the scores for
offer-making? SPA believes that there could be a risk in having a different measure for monitoring
to that used in offer-making. This could invite confusion and further separation between Planning
and Admissions. Management information should be used to integrate practice, not to enhance
silos. There could also be a risk that managers will only understand the metric and so may insist on
entry requirements being represented in that format.
2. What would be in the impact of this recommendation on you/your organisation?
If HEIs start to use the scores anyway, for offer-making, but without this being recognised as
legitimate use, this would affect SPA significantly in terms of our good practice work with
institutions.
3. To what extent do you agree that this recommendation supports fairness, transparency
and efficiency in HE admissions?
Strongly
agree
Agree
Neither agree
nor disagree
Fairness
x
Transparency
x
Efficiency
x
Disagree
Strongly
disagree
SPA thinks this answer depends on what these proposed metrics are intended to do; this is not
made clear in the consultation document other than to say they will be ‘for management
information purposes’. In terms of the benefit to institutions in having this metric, we can see a way
in which it could be used to analyse trend data in relation to the level of offers made, accepted and
ultimately to identify average ‘points on entry’. Although in reality there are often differences
between the points total of the offer made, the points total the applicant achieves and is confirmed
at, and their actual total points on entry (as they may be taking qualifications which are not
included as part of their offer). In the Briefing Paper which came with the consultation document it
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states that one of the benefits is to ‘provide funders, regulators and policy makers with a reliable
and robust metric to enable the comparison of HE entry qualifications.’ So, we could reasonably
ask, who is this actually for? SPA would also question the transparency of a separate metric for
those working ‘behind the scenes.
4. Do you think that any dimensions other than academic demand and qualification size
should be considered within HE management information metrics?
Don't know.
Again, we think this answer depends on what these metrics are intended to do and this needs to
be more clearly defined before suggestions can be made as to additional dimensions.
5. Please use the space below to outline what communications and guidance you feel
would be necessary to support implementation of this recommendation.
As this information will have to be in the public domain, UCAS must ensure that it isn’t used by
others for inappropriate purposes as the Tariff is now e.g. by some employers to filter out interview
candidates, and for perverse usage e.g. in league tables. HEIs would need time to fully
understand the implications of this new measure as decisions to run or to close courses can be
taken on the basis of such information.
Recommendation 5
The Qualifications Information Review recommends the provision of a UCAS annual report
on the use of qualifications within HE admissions
1. To what extent do you agree, in principle, with the recommendation for UCAS to produce
an annual report on the use of qualifications within HE admissions?
Agree.
SPA agrees in principle that an annual report on the use of qualifications within HE admissions
could be helpful to the sector. Care would be needed, however, to avoid any assumptions,
particularly between qualifications taken by applicants and qualifications actually used in decisionmaking (e.g. a large number of accepted applicants with General Studies do not necessarily mean
it is used by the HEI).
2. What would be the impact of this recommendation on you/your organisation?
SPA would find this a very interesting publication.
3. To what extent do you agree that this recommendation supports fairness, transparency
and efficiency in HE admissions?
Strongly
agree
Agree
Neither agree
nor disagree
Fairness
x
Transparency
x
Efficiency
x
Disagree
Strongly
disagree
As presented, SPA is not sure how this will benefit fairness, transparency and efficiency in HE
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admissions.
When a less familiar qualification is presented as part of an application, admissions staff will
research the details of it to establish whether an offer can be made (this happens with varying
degrees of effectiveness in different HEIs and can be helped by centralised admissions decisionmaking structures as dedicated staff can have this written into their roles). If the data collection for
this annual report asks HEIs which qualifications they would like including in the new grade
equivalences table, there is no benefit to them in including ones where they’ve already done the
research. There is a benefit to the wider HE sector, and as such UCAS may receive the data from
HEIs, but we think UCAS as a shared service should be proactive in identifying new qualifications
and ensuring they are added to the grade equivalences tables. To us the responsibility for this
should sit with UCAS, rather than with HEIs.
Depending on when admissions staff are asked for the information, they may not respond fully and
in sufficient detail to ensure a qualification is included. If the recommendation for qualifications to
be demand rated in the future is based on the analysis of the qualifications applicants are applying
with as outlined in point 11.3, is it not the case that HEIs will already have decided these
qualifications have utility for progression to HE? What then is the benefit to HEIs in this
retrospective demand-rating? Equally, we think HEIs should be able to contact UCAS to ask them
to ‘demand rate’ a qualification, at any stage in the admissions year.
4. Please share any comments you have on the scope of the annual report as outlined in
the consultation document.
No response
5. When in the academic year should this report be published so that it can be most helpful
in supporting HE admissions?
If the report is intended to help HEIs to widen the range of qualifications for which they make offers
and to report on changes to existing qualifications and introduce new ones, it would be most
helpful just before the start of a new admissions cycle, when HEIs are planning their offer-making
strategies for the year to come, or for their prospectuses in the year after that.
6. Please use the space below to outline what communications and guidance you feel
would be necessary to support implementation of this recommendation.
HEIs would need very clear guidance about what information and data they would be required to
provide, and when. Ideally this should be included in the UCAS annual data collection exercise, to
ensure data is collected once and used for many purposes. The timing and coordination of this
across different units within UCAS which ask HEIs for data and information would be crucial to the
report’s effectiveness and success.
Recommendation 6
The Qualifications Information Review recommends the provision of optional admissions
tools for those HEIs wishing to make more flexible grade-based offers, subject to
consultation with the sector.
1. To what extent do you agree, in principle, with the recommendation to provide optional
admissions tools for those HEIs wishing to make flexible grade-based offers?
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SPA supports this recommendation in principle, but only if these optional admissions tools are free
of charge to all HEIs, applicants and advisers.
2. What would be the impact of this recommendation on you/your organisation?
SPA is likely to receive more general enquiries from the public about how HEIs make decisions,
particularly if separate tools for HEIs make it less clear for applicants.
3. To what extent do you agree that this recommendation supports fairness, transparency
and efficiency in HE admissions?
Strongly
agree
Agree
Neither agree
nor disagree
Fairness
x
Transparency
x
Efficiency
x
Disagree
Strongly
disagree
Will these optional tools be free of charge? If they are not, it might be prohibitive for some HEIs
and lead to inequities if some institutions have access to more sophisticated tools to aid
admissions decision-making. If they aren’t free of charge this wouldn’t be consistent with
transparency and could be a threat to widening inclusion if all HEIs don’t have access to them.
SPA believes that any comparator tool should be freely available to all applicants and advisors, not
just HEIs, for their usage to be transparent. It would be a retrograde step if applicants did not know
whether or not their qualifications were acceptable before submitting an application. Taking the
example given above, an applicant with a mixed profile of qualifications should be able to work out
if they meet University X’s requirements before applying, not wait for an admissions tutor to use the
on-line calculator. UCAS must be mindful of the varying levels of IAG available to different
applicants, particularly some WP cohorts, and ensure the support available enables them to fully
understand any information presented to them via these optional tools. On-line and/or telephone
support must ensure they have access to tools which provide the same information and outcome
as that available to HEIs, albeit this may be in a different format.
It should be noted that these tools will be unable to take into account HEIs’ contextual data
elements of admissions decision-making.
4. Would you/your organisation want to use such tools within admissions?
Not applicable.
5. Please use the space below to outline what communications and guidance you feel
would be necessary to support implementation of this recommendation.
Staff development would need to be provided for HEI staff in the effective use of these tools, to
ensure they are used consistently and fairly.
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Realising the full potential of the review outcomes:
1. UCAS is committed to ensuring its products and services are strengthened in light of
any agreed changes, so the benefits of the new qualifications information system are
fully shared with learners, applicants, schools and colleges. Please use the space below
to share any comments or suggestions regarding ways in which UCAS products and
services might be revised in light of the proposals made in the consultation document.
SPA supports the principle of ‘collect once and use many times’ in terms of data collection, as
outlined in our response to consultation question 5. UCAS should ensure that its products and
services are organised in such a way as to avoid duplication in terms of requests for data and
information from HEIs. UCAS should also ensure any new products such as the optional
admissions tools identified in consultation question 6 are equally available to all HEIs, applicants
and advisors and that cost is not a prohibitive factor.
2. Do the proposals outlined in the consultation document take sufficient account of the
education and HE environment in your part of the United Kingdom?
SPA works with HEIs across the UK and as such is conscious that external debates are sometimes
very English centric and A level focused. This consultation is an ideal opportunity for UCAS to
develop a system which is truly UK-wide, covering qualifications in Northern Ireland, Scotland and
Wales as well as in England, and ensuring the information that HEIs have access to supports fair
and transparent admissions decision-making across the whole of the UK HE sector.
The consultation states in recommendation 1 that QIPs will be generated for key international
qualifications; however it is SPA’s view that while this may be desirable, the first priority should be
to ensure that QIPs are generated for all UK level 3 qualifications. UCAS will also wish to consider
some level 4/5 qualifications which are commonly used as routes to degrees e.g. foundation
courses; HNDs; DipHE.
3. Do you believe that the proposals outlined in this document will be sufficiently flexible
to accommodate any future changes to the UK qualification and examination systems?
SPA thinks the key to this is in ensuring that UCAS qualification specialists are involved in any UK
qualifications developments, through initiatives such as the National Curriculum Review in England
and Curriculum for Excellence in Scotland.
There is also a key role for a group such as the UCAS Qualifications and Progression Group
(previously the Curriculum Development Group) to enable UCAS to be proactive in providing
qualifications information to the HE sector, when qualifications change or new ones are introduced.
We do not think it is made clear from the recommendations, how future qualification changes will
be represented, as the annual report as presented appears to be a retrospective collection of
qualifications data. If a brand new qualification is developed, will it have to wait until a cohort has
successfully completed before there is enough information to develop the QIP, equivalence and
metric, or is there a mechanism which will allow HEIs to consider that first cohort in their entry
requirements?
4. Please use the space below to detail any additional qualifications information services
that you would like UCAS to provide.
UCAS as a shared service for HEIs should ensure it has mechanisms in place to provide new
qualifications information on request, rather than waiting for HEIs to ask for it.
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Implementation and resourcing:
1. The introduction of new qualifications information services should deliver efficiency
gains for HE providers. Please outline any views you have on the perceived efficiency
benefits of the proposals and suggestions for how any disadvantages could be
minimised.
SPA agrees that any new qualifications information services must deliver efficiency gains for HE
providers. We think it is important that UCAS carries out a cost-benefit analysis to identify the
extent to which these proposals will do this, for example, the establishment of the new
qualifications advisory group as in recommendation 3 – where is the evidence to demonstrate that
this new group will be more efficient than the current Tariff methodology? It is well known that the
current Tariff methodology has been prohibitive in terms of cost, for some awarding organisations.
Any new system must be accessible in terms of cost, for any new qualification to be assessed and
included. Only by providing such a system can disadvantage to qualifications and to learners be
avoided.
2. The cost of developing, delivering and running the new service will be met by UCAS.
This means that there might need to be a small increase in the capitation fee. If you work
for an HEI, would your institution be willing to pay a small increase for access to this
enhanced service?
No response.
3. If the proposals are agreed, UCAS plans to support implementation through a
comprehensive, long-term engagement programme aimed at HE admissions staff,
learners and their advisers. We would welcome comments on the particular needs of
different stakeholder groups, especially more mature learners and those learners who
have limited access to high quality information and advice.
Some aspects of the recommendations appear potentially problematic for some learners.
For example, in recommendation 3 where the proposal is that applicants who are not taking A
levels will need to refer to ‘the equivalences outlined in the UCAS scale’. More mature learners and
those learners who have limited access to high quality information and advice are the very ones
who we need to ensure can understand the qualifications system, in terms of applying to enter HE.
SPA’s concern is that these groups could be further marginalised by a system which isn’t
transparent about their specific qualifications and appears to under-value them, if the only up-front
entrance requirements provided are for A levels. SPA thinks this is a key issue in terms of
vocational and less traditional progression to HE e.g. what about those learners applying with
APEL, APL, APCL and RPL? Whatever the HE sector recommends in terms of its response to this
consultation, the long term engagement programme must ensure these groups of students are an
integral part of that, rather than an afterthought.
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