Comments on the Draft DSA Guidance for 15/16 issued October 2014
Dear BIS,
1. The £200 contribution destroys a previously fiscally-fair student finance product.
The DSA is non-means tested and intended to cover the additional costs a student is obliged to incur. By introducing a requirement for students to pay £200 towards a computer that is required to run assistive software, you are introducing means-related element to the DSA. Arguably, the student is now obliged to incur a cost of £200.
2. Students not given fair notice of changes
The introduction of the £200 levy has been enacted at very short notice for students. Your own Equality Analysis notes that you took note of the HEI arguments that they would not be ready for changes in AY 15/16. It appears students are expected to have been ready, without notice. The students applying for places in 15/16 had no knowledge of the £200 – there have been no details issued to advisers, no information and advice issued, no mention of the £200 in the funding body publicity and nothing on directgov. This is very close to the Access to Work situation where ‘secret rules’ and unannounced changes have been challenged.
3. Cuts to IT peripherals is premature
The fact that HEIs have been given a delay period based on ‘not being ready to meet their legal requirements’ seems at odds with the introduction of exceptional case only rules for IT peripherals (printers and scanners) for students with the expectation that the HEI will provide meet need. The HEI’s told you: they will not be ready. It will be an exceptional university that is able to provide 24 hour accessible to all printing and scanning facilities in September 2015.
4. Book allowance: exceptions, or not?
Connected to the point above is the 'textbooks: no exceptions' statement in the draft guidance. This is at odds with the Equality Analysis promise that exceptional case will used to mitigate problems with books.
5. Mobility Training – DSA, or not?
Page 49 describes mobility trainers as if it is funded via DSA. Annex B notes mobility training as an example of a reasonable adjustment.
6. Specialist One to One Study Skills Support – “a reducing level of support “is not clear
Annex B states that the HEI can be expected to provide the following as a reasonable adjustment: ”Specialist one-to-one support for students with SpLDs available from the institution for one hour per week, per SpLD student’”. This is presumably the base-line for the HEI funded support throughout the whole course, with the DSA being expected to pay for additional sessions. Assuming the HEI provision remains constant at one hour per week why is there an expectation that the DSA funded hours will reduce? This does not take into account increased cognitive demands of course as the course moves to higher levels.
7. Exceptional case process – timescales needed
As above, the premature introduction of IT peripherals cuts will mean that there will be a large number of these cases based on ‘HEI cannot provide’ argument. There will also be students who request exceptional cases to be made for Macs and tablet computers (as they do now). There need to be some stated time scales for decisions on the exceptional case element of need assessments, otherwise it may be quicker to submit a needs assessment and get refusals first-off and advise the student to trigger a complaint against the funding body.
Amanda Kent
DSA needs assessor
