Student Loans Company DSA cut enforcement process : initial details

Student Loans Company have released the answers to frequently asked questions about the forthcoming cuts to Disabled Students Allowances. It is in fact the government department BIS who are behind the plans to cut printers, scanners, course software, book allowance - but the Student Loans Company are the organisation who will be enforcing the cuts and they now show outward signs of constructing a process that will make at least some of the modernisation measures workable. The SLC will be in charge of deducting £200 from the cost of the computer identified as part of the DSA needs assessment and of telling the student they cannot have the full cost of a computer through the DSA. That will put the SLC in the position of cut enforcers. There will be no appeal on the £200 because it has already been embedded into an amendment of the student finance regulations. SLC will always tell students they cannot have the full cost of a computer from the DSA. Under the current system, a student who wishes to purchase a computer from a non-DSA QAG supplier has to get an agreement from SLC on the amount that they are willing to reimburse. The amount seems to be based on either the lowest of the three computer prices in the DSA needs assessment report, or on a figure considered reasonable by SLC which is not related to an individual needs assessment. It will be interesting to see how SLC handle this in the future because there could be large numbers of students making a routine enquiry about open market reimbursement.

University practice changing ahead of DSA cuts

University of Salford have released detailsabout how and why they are changing their approach to accessible course delivery. ALL students will now have access to PowerPoint slides before lectures, fair warning of timetable changes and preparation time for class discussion. No more Individual Support Plans.

Every university is being challenged in the name of DSA modernisation which aims to rebalance the responsibilities and the costs of inclusive and accessible higher education.

In the frequently asked questions, the University states that DSA is being removed for students with specific learning difficulties; that is not the case (at least not if we assume the information in the public domain is correct). The Equality Analysis states that those with mild dyslexia are deemed to be outside the scope of DSA funded support, those with moderate to severe levels of specific learning difficulty will be able to claim DSA. Furthermore, in a clause added in December 14 the “impact of the learning environment” has been added as a factor in “complexity’ thus providing an argument for ‘mild’ dyslexia being ‘moderate to severe’ in a complex learning environment. 

BIS update Equality Analysis on Disabled Students Allowance

BIS updated the Equality Analysis on thechanges to Disabled Students’ Allowance on 16th December 14. 
Some of the statistics have been updated since the October version (section 19).  

The most significant addition to the content is at section 70:

“Consultation with stakeholders on this proposal has highlighted that the complexity of a student’s Specific Learning Difficulty is related primarily to the impact of the learning environment, rather than the severity of the impairment. Whilst it is the case that inclusive learning environments and anticipatory reasonable adjustments will remove the reliance on DSAs for some students with a Specific Learning Difficulty, this is unlikely to relate to the severity of their learning difficulty. Therefore, for the purposes of these reforms, students with Specific Learning Difficulties are assumed to be part of the wider disabled student body that will be affected by the Non-Medical help proposal and will not be treated as a distinct group. “

This new point appears somewhat at odds with the one above it, which states that students with ‘mild SpLD’ will be assumed to be a distinct group:

“We propose that DSAs funding remains available to students presenting with moderate to severe levels of Specific Learning Difficulties, as evidence by the range of tests, and that institutions make sufficient anticipatory and individual reasonable adjustments to meet the needs of their students presenting with a mild Specific Learning Difficulty.”

This does not change the intention of the original ‘DSA modernisation’ proposal that “Students with Specific Learning Difficulties will continue to receive support through DSAs where their support needs are considered to be more complex.” The Equality Analysis of October 14 clarified that ‘more complex’ means moderate to severe. The December 14 addition does not remove the university’s responsibility for meeting the needs of students with mild SpLD.

The ‘non-medical help proposal’ referred to in section 70 comes into force in academic year 16/17 and is that “institutions to provide any individual lower level support needed by disabled students” , effectively cutting  ten types of support from DSA funding (section 64 and 65). What the Equality Analysis confirms is that all disabled students will be affected by this cut – a student with severe dyslexia will not be able to have a note-taker funded through DSA, and neither will a student with a severe visual, hearing, physical or mental health impairment.

DSA delay for students caused by delay in finalisation of administration guidance

Students face delays in the processing of Disabled Students Allowance applications for this funding round (for courses starting September 2015).

Changes to the type of equipment and support services available through the Disabled Students Allowance were announced in April 2014. Between October and December Statutory Instrument passed through Parliament, confirming that all students will have to meet a £200 shortfall on computers needed to run specialist software. As promised, a version of the document that sets out how changes are to be reflected in needs assessments and administered by the main funding body (Student Loans Company) was made available for comment. However, it was not widely circulated, it was not clear whether open comments or 'usual channel' stakeholder group comments were being asked for, and was difficult or impossible for disabled peoples' group to locate the document or to understand what was being asked for. Shortly after the news of a legal challenge on DSA cuts centred on lack of appropriate consultation, we have the news that the comments period for for the draft administrative guidance has been extended to 20th Feb. The DSA application forms, however, have already been released. This means that DSA needs assessment reports and the agreement to recommendations will be delayed while we wait for the release of the finalised version of the rules.