Wednesday, 31 December 2014
Transparency
Law firm LeighDay have succeeded in getting the DWP to publish guidance on the rules that are used to determine Access to Work funding. Apparently these have been 'secret' and therefore clients have been unaware of the original rules and changes to rules.
For potential Disabled Students Allowance clients there has been a similar situation with:
lack of notice about the change in eligibility rules requiring medical evidence to demonstrate disability as deceived in the Equality Act,
no details about cuts to student equipment in academic year 15/16 meaning students applying for courses do not know what support they can expect to receive,
no prior warning of the £200 laptop tax payable by disabled students applying for DSA
BIS can be challenged on this via feedback/comment on the draft of the new DSA guidance which HAS been published.
http://www.leighday.co.uk/News/2014/December-2014/Government-makes-Access-to-Work-Scheme-guidance-pu
Tuesday, 30 December 2014
'Guidance' on policy implementation guidelines
The administrative Guidance Chapter on Disabled Students Allowanceare the official guidelines for the implementation of policy on the studentfinance regulations relating to application and entitlement to DSAs.
DSA Guidance Chapter that relates to the adminstrative work of the Student Loan Company is updated every year, usually by some unseenprocess and without any formal notification (we just have to ‘be aware’ that itappears on a website some time before the start of the actual academic year).This year DSA is being ‘modernised’ so sight of and comment on the draftadministration plans has been permitted as part of the consultation withstakeholders.
When DSA was administered mainly by the local educationauthorities the Guidance was edited and issued by the relevant governmentdepartment with Higher Education/student finance responsibility. The transferof the administration of student finance to the centralised system run by theStudent Loans Company saw some SLC input into the Guidance but control iscurrently with BIS. The SLC have their own subset of administrative rules(‘decision matrix’).
Student Finance Wales, the Research Councils, the NHS and the NI Library Boards and Student Awards Agency Scotland have their own sets of adminsitrative guidance. This will create some interesting discrepancies between 'DSA students' in the coming academic year 15/16 because only Student Finance England Students will have to contribute £200 towards a DSA computer and be subject to an 'exceptional case process' to prove the case for printers, scanners or higher cost computers.
Sunday, 28 December 2014
consultation, not Consultation - the story so far on opportunity to comment on DSA modernisation
BIS have a code of practice about consultations.
Apparently the March 2013 document about Targeted Student Support listed in 'consultations' that asked questions about Disabled Students Allowance and equipment fell outside the this code:
"We need to make sure funding reaches those experiencing the greatest disadvantage or facing the greatest barriers to a higher education. This call for evidence provided us with a less formal way to gather views to help develop our policy on targeted support.
We received around 250 responses from a wide range of stakeholders. We’ll consider the many suggestions received in any future review of targeted support funding. We won’t be publishing a formal response."
No formal policy consultation but the questions about computer availability and the Disabled Students Allowance were nevertheless used to develop policy. The lack availability of evidence or conclusions seems somewhat at odds with a 2012 set of guidance instructions on Consultation Principles which suggests "Every effort should he made to make available the Government's evidence base at an early stage to enable constestability and challenge."
The concept of consultation emerged again in the April 2014-DSA modernisation announcement. "We will be consulting with specialists in the sector to ensure that Specific Learning Difficulties (SpLD) students understand the type of support they can expect to receive and who will provide it." We have not seen any outcomes from these consultations in the public domain but we do know from anecdotal comments that representatives from various groups were invited to meetings. We also know from answers to questions that individuals, stakeholders and interested parties lobbied using various Parliamentary channels from April onwards.
The April 14 SSIN told us that "BIS will be engaging with HEFCE and sector colleagues on how to deliver these changes. This will take place via the usual channels (ie via the SLC, the SLCs Disabled Students Stakeholder Group (DSSG) and sub groups, BIS' Student Support Stakeholder Interest Group (SIG), and via the Disabled Students Allowance Quality Assurance Group (DSAQAG)". It is not clear whether 'the usual channels' sought group views from their respective memberships or communicated any outcomes.
The June SSIN noted further consultations. "BIS are in discussion with the Department of Health and the Devolved Administrations about the new BIS arrangements for English students. "
On Sept 12th 2014 Greg Clark issued a written statement to Parliament summarising the consultation outcomes: "During the summer, I and the Minister of State for Disabled People have listened carefully to suggestions from representatives of disabled students. I have also listened to the views and concerns of representatives across the higher education and disability sectors, as well as receiving representations from honourable members."
The result of the summer-listening exercise was that only Universities got a temporary reprieve, and "in particular" on NMH. The students have been left with a £200 contribution towards computers and cuts to IT peripherals, books, consumables and accommodation as well as no Mac computers for students enrolling on Mac-based courses.
Details about why there will be continuance of non-medical helper support for another year while students experience cuts to the range of equipment and general allowance items is encapsulated in the Equality Analysis issued in October 2014 , a document confirming that all of the proposed changes will impact on disabled people applying for student support (point 144).
Further details of changes to DSA are contained in the October 2014 draft DSA Guidance Chapter for academic year 14/15 which interprets the Student Finance Regulations for the purposes of administration. Although it is updated every year, the draft Guidance is not usually seen in the public domain and there is therefore no routine or standard mechanism for response; 'the usual channels' may have been asked for comment but some of the groupings operate under secrecy rules that prevent open consultation with stakeholder group members; any queries or requests raised via attendees of the DSSG groups are closed.
There was no deadline for responses on the SFE Practitioners website when the draft Guidance was first issued. However, just before the Christmas break, a response date of the 14th January appeared and at the same time BIS issued an email via a 'stakeholder' address that sets a date for submission for comments (9th Jan 2015).
As the year closes, individuals, groups, interested parties etc and have until January 14th at the latest to comment on some aspects of the embodiment of policy - the draft Guidance. Like all 'consultation' this is mainly a token exercise in terms of actually having any effect on policy because two of the big items (the change of eligibility criteria and the £200 laptop tax) passed into law via a Statutory Instrument in early December 2014. However, there is a chance to try to influence the administrative detail. The devil is in the details.
No formal policy consultation but the questions about computer availability and the Disabled Students Allowance were nevertheless used to develop policy. The lack availability of evidence or conclusions seems somewhat at odds with a 2012 set of guidance instructions on Consultation Principles which suggests "Every effort should he made to make available the Government's evidence base at an early stage to enable constestability and challenge."
The concept of consultation emerged again in the April 2014-DSA modernisation announcement. "We will be consulting with specialists in the sector to ensure that Specific Learning Difficulties (SpLD) students understand the type of support they can expect to receive and who will provide it." We have not seen any outcomes from these consultations in the public domain but we do know from anecdotal comments that representatives from various groups were invited to meetings. We also know from answers to questions that individuals, stakeholders and interested parties lobbied using various Parliamentary channels from April onwards.
The April 14 SSIN told us that "BIS will be engaging with HEFCE and sector colleagues on how to deliver these changes. This will take place via the usual channels (ie via the SLC, the SLCs Disabled Students Stakeholder Group (DSSG) and sub groups, BIS' Student Support Stakeholder Interest Group (SIG), and via the Disabled Students Allowance Quality Assurance Group (DSAQAG)". It is not clear whether 'the usual channels' sought group views from their respective memberships or communicated any outcomes.
The June SSIN noted further consultations. "BIS are in discussion with the Department of Health and the Devolved Administrations about the new BIS arrangements for English students. "
On Sept 12th 2014 Greg Clark issued a written statement to Parliament summarising the consultation outcomes: "During the summer, I and the Minister of State for Disabled People have listened carefully to suggestions from representatives of disabled students. I have also listened to the views and concerns of representatives across the higher education and disability sectors, as well as receiving representations from honourable members."
The result of the summer-listening exercise was that only Universities got a temporary reprieve, and "in particular" on NMH. The students have been left with a £200 contribution towards computers and cuts to IT peripherals, books, consumables and accommodation as well as no Mac computers for students enrolling on Mac-based courses.
Details about why there will be continuance of non-medical helper support for another year while students experience cuts to the range of equipment and general allowance items is encapsulated in the Equality Analysis issued in October 2014 , a document confirming that all of the proposed changes will impact on disabled people applying for student support (point 144).
Further details of changes to DSA are contained in the October 2014 draft DSA Guidance Chapter for academic year 14/15 which interprets the Student Finance Regulations for the purposes of administration. Although it is updated every year, the draft Guidance is not usually seen in the public domain and there is therefore no routine or standard mechanism for response; 'the usual channels' may have been asked for comment but some of the groupings operate under secrecy rules that prevent open consultation with stakeholder group members; any queries or requests raised via attendees of the DSSG groups are closed.
There was no deadline for responses on the SFE Practitioners website when the draft Guidance was first issued. However, just before the Christmas break, a response date of the 14th January appeared and at the same time BIS issued an email via a 'stakeholder' address that sets a date for submission for comments (9th Jan 2015).
As the year closes, individuals, groups, interested parties etc and have until January 14th at the latest to comment on some aspects of the embodiment of policy - the draft Guidance. Like all 'consultation' this is mainly a token exercise in terms of actually having any effect on policy because two of the big items (the change of eligibility criteria and the £200 laptop tax) passed into law via a Statutory Instrument in early December 2014. However, there is a chance to try to influence the administrative detail. The devil is in the details.
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