…to the Inclusion in HE blog. A place for discussion related to removing barriers to higher education.
It should be applauded that the minister for HE has cast a spotlight on the provision for a growing numbers of students who are identifying as having mental health difficulties. However, what isn’t clear is why a specific group of disabled students should gain so much ministerial attention and (moral) panic within headlines of major newspapers. I thought a good starting point might be an analysis of the extent of the problem by using freely available statistics from the Higher Education Statistics Agency (HESA).
This table shows the relative increase in disclosure of mental health difficulties (MHD) alongside disclosure of specific learning difficulties (SpLD)(dyslexia etc.), the overall increases in the numbers of students in general and the disclosure of all disabled students. (N.B. these are only first year UK domiciled students as the figures for all students are much harder to obtain from the HESA website – but they are a good enough sample to show the size of the effects).
What is clear is that there is cause for celebration in terms of the sector’s duty to implement the Equality Act 2010. For example, overall there has been almost a five-fold increase in the level of students who were willing to disclose some type of HESA-categorised disability. This is a great achievement for the UK in general as it is more than likely a combination of the increased awareness and acceptance of conditions such as dyslexia, autistic spectrum disorders and MHDs. Students are being diagnosed with these conditions much more frequently and are increasingly willing to tell someone about it.
Going back to the figures, in terms of SpLD there has been a 13-fold increase and for students with MHD an almost 19-fold increase. Maybe this is where the panic has come from? However, a very quick ‘eyeballing’ of the numbers shows that between 1994/95 and 2005/06 disclosure of SpLD increased five-fold which is a similar rate of increase as that which we have seen in the last 8 year period for MHD disclosure. However, there hasn’t been (or rather there wasn’t) a similar level of panic in the sector when the increases in dyslexia were identified. No minister for higher education accused the sector of failing students with SpLD as far as I am aware, although one has recently mentioned the importance of the support he received when he found out he was dyslexic at school. There are still twice as many students in HE with SpLDs than with MHD, but no headlines appearing about their support?
What is encouraging is that most universities are now well staffed to work with students who disclose MHD, often with a significant level of counselling resource and more often than not a multi-disciplinary team under the auspices of wellbeing. These resources have increasingly been bolstered by additional services provided through the NMH element of DSA funding through specialist mentoring provision. HE still seems to be the richer cousin compared to other levels of the education sector when it comes to resourcing support for SEN (a perverse quirk of the education system – fight your way into HE and get good support having contended with the continued post code lottery in schools and colleges). This was not the case for SpLD students in HE in 1994 when these statistics were first collected. There was very little provision for those students 25 years ago. Most universities now provide reasonable adjustments for SpLD students such as extra time for exams and assignments (some HEPs) and extended library loans, as well as utilising the NMH allowances from DSA to pay for specialist tuition. But it would be useful to see a comparison of the resources available for these two groups of students within HEPs.
Something else to think about: I haven’t analysed the figures for all the other categories of disability here, however policy makers ought to consider the statistics in a more holistic fashion before accusing the sector of failing to adequately support one particular group. The picture is much more nuanced that it might first appear. For example, it should be noted that there are only 936 more first year deaf students enrolling in 2016/17 (2080) than there were in 1994/95 (1144). Perhaps, not so surprising when you consider the rates at which deaf students gain 5 A*-C GCSEs. Should we be just as morally panicked? Maybe Sam Gyimah ought to tell Vice-Chancellors that prioritising these students is not negotiable? Or maybe he should just be concerned about all disabled learners in all levels of the education sector?
If inclusive teaching and learning is to gain traction in UK HE, support for equality needs to be been given more than the cursory glance during quality assurance that it has been afforded in the past.
The QAA is to remain as the agency in the UK that will oversee ‘quality and assessment standards functions’. With a new ‘fully revised’ version of the UK Quality Code due to be published in late 2018 I thought it would be interesting to look back at the role which quality audit has taken in ensuring disabled students get an equitable experience of HE. It’s particularly important at the moment with such an emphasis being placed on inclusive teaching and learning and a move away from the DSA funded support for individual students.
In October 1999, the QAA published ‘Section 3: students with disabilities’ of its code of practice for quality assurance which audit teams were to use when ‘inspecting’ the provision of HEPs. The section contained 24 precepts which covered a whole range of facilities including precepts related to the delivery of academic programmes and examinations and assessments. An example of this being precept 10:
The delivery of programmes should take into account the needs of disabled people or, where appropriate, be adapted to accommodate their individual requirements. (QAA 1999, p. 13).
In 2005 Riddell and colleagues noted that academic staff were aware of the section of the code which focussed on disabled students and by 2007 observed that the section had been recognised as playing a role in the development of provision within HEIs. But teaching staff also expressed resentment at being told what to do by an external agency and for some, quality assurance processes overall are anathema to their understanding of the essence of HE provision.
A review carried out by the QAA in 2009 of 129 of its institutional audits is somewhat equivocal in relation to the impact of section 3 of the code (QAA, 2009). Whilst it was reported that 95% of audit documents mentioned disabled students, it also noted that there is no requirement to report separately on support available and therefore there were no references made to this provision in sections within audits reports which related to good practice. Nor were there any recommendations for action made by the auditing teams (QAA, 2009). It is perhaps indicative of the approach taken to support for disabled students within institutional audits that the report mentions ‘only a small number of the institutional audit reports specifically identified features of good practice in the area of meeting the needs of students with disabilities in aspects of learning and teaching’ (QAA, 2009, p9).
My own experience of QAA audits and of other quality assurance processes in HEPs is that disabled student support is given a very cursory glance. Disability staff in HE are often pulled in at the last minute as an afterthought. I’m sure many readers will have experienced taking or making a phone call a week before such a process is due to take place, when the question ‘what are we doing to ensure disabled students are supported properly?’ is asked. This is despite quality assurance relating to equality issues being ignored for the previous 4 or 5 years since the same processes were undertaken.
In 2010, an updated version of the QAA section was published which contained precepts that reflected a more inclusive style and which paid heed to the social model of disability and the need to remove barriers to participation (QAA, 2010). However, in 2013 the specific section on disabled students was removed from the code and replaced with mentions within ‘chapter B4: enabling student development and achievement.’ This new chapter also amalgamated chapter 8 which was related to careers advice. These topics are odd bedfellows. At the same time references to disabled students were included within the chapters which specifically refer to teaching and learning and assessment and prior learning.
Whilst embedding references to disability within the other chapters of the code represents a more inclusive approach the move was perhaps questionable given the evidence from the QAA’s own review of audits. A more prudent approach might have been to ensure compliance to the existing separate section. It’s always a difficult balance to get right – being inclusive by embedding these issues throughout such processes whilst not losing the essence of what you are trying to achieve. In my opinion we went too far at that point in time.
Chapter B4 also pushed HEPs to ensure that they are pursuant of their obligations under existing legislation such as the Equality Act 2010. But there is very little joined up thinking around the EA2010 and the practice of teaching and learning. Once responsibility for this aspect of quality assurance is farmed out in such a way to other agencies or parts of the university which oversee equality policy, it gets lost with the myriad issues which academic departments are dealing with and becomes the bolt-on process which gets left as an afterthought.
If we are to make progress on inclusive teaching and learning during this next phase of quality assurance, it is imperative that it is embedded within the core processes of audit and that auditing teams and subsequent reports put it up front and central.
‘there does appear to be a bit of a postcode lottery when it comes to offering support’
I thought I would try to explain the process of identifying specific learning difficulties/differences (SpLD)/dyslexia for readers who do not have an in-depth knowledge of how support systems work in HE in the UK. Many education providers face an uneasy challenge of identifying learners with additional support needs whilst struggling to provide properly funded support mechanisms.
The system that most HEPs have in the UK is that students are directed towards the disability service (or the name given to it in their place of study) to be ‘assessed’. Many students (and often their parents) start asking questions at open days, often stating that their school did some sort of assessment and it was used to give them extra time in exams or they were told they weren’t dyslexic but they’re still struggling. Or they come at some point in the academic year (either during Freshers’ week) or when they start struggling.
The second tranche of students usually come because of a referral from their academic department after they have handed in an essay. By the way, this is a reason not to panic in central services, as a steady stream of students emanating from academic colleagues is a sure sign that the message around available support is getting through.
Most central services staff will then do some sort of screening test which will involve an interview with the student to discuss their educational experiences and the reasons why they think they might be dyslexic and some sort of screening schedule (usually a list of questions with indicators). However, in my experience it is rare to turn a student down at that point: more usually they will show some kind of issue and be referred to an educational psychologist. This will either be someone who comes onto campus from an external organisation (I have used the Educational Guidance Service in the past) or they will be asked to visit a local centre such as those run by the British Dyslexia Association.
The assessment is usually around £300 which is a significant amount of money for students facing years’ of tuition fee repayments once they leave HE. Students must weigh up the costs of paying for this against the benefits of identification and all that comes with it in terms of self-understanding and support systems.
But many HEPs provide some financial support for this process. From a cursory search using Google (and contrasting HEPs towards the opposite ends of the Guardian league tables): at Oxford University support is available through the ‘SpLD fund’ – it appears from the information I could find that the costs will be met in full and up to a year after the assessment was carried out; and at York St John University it appears that the student must pay the full costs of the assessment (£284) and arrange their own appointment. (Please let me know if the information is incorrect for either of these examples).
So there does appear to be a bit of a postcode lottery when it comes to offering support and there is a question over the extent to which staff within HEPs act as street level bureaucrats when developing systems of support in the face of unlimited demands for their services. At the most inclusive end of the spectrum, are HEPs in which a screening is offered across all students. In some further education colleges for instance, an initial literacy test is administered to all students upon enrolment on a course of study which might funnel students to support for English language skills including support for SpLD. The opposite to this would be a provider where there is no financial support or limited referral processes.
When I first came into HE 20 years ago, there were limited resources in the UK and the institution I worked at offered limited help with the referral process. A fund was available, but it was means-tested, and the student was asked to go off campus to a centre and arrange their own assessment. It wouldn’t have been in my best interests in terms of student expectations if I’d screened everyone, because there weren’t the resources available to support those students. They were troubling times for me, professionally and ideologically!
The current context means that these systems are once again being opened up to funnelling because demands are ever-increasing (disabled student disclosure has risen hugely in the last 30 years), resources are being stretched (in England at least where the funding model is being ‘modernised’), and the model of central support is being questioned in order to move towards more inclusive teaching and learning. Some HEPs are already reducing the amount of funding they provide for assessments of SpLD or are outsourcing their support services to commercial operations. The question is how do HEPs maintain the balance between making support available on a mass basis with limited financial resources whilst ensuring that they abide by their legal obligations and commitment to social justice, widening participation and inclusion.
Most policies present difficulties for implementation which result in tensions or dilemmas. HE disability policy is no different and this post highlights one such difficulty. The first tension is that there is some kind of student choice built into the system of DSA funding. When I first started in HE nearly 20 years ago there was ‘real’ student choice at least in the university I was working in. Disabled students could choose to organise their own support in a similar way to that which direct payments allowed. This was mainly because we didn’t have the resources nor the infrastructure to take on that responsibility in the disability office. However, it was often repeated to me (mainly by my manager) that the money belonged to the student and therefore they were responsible for using the money as they saw fit (how things have changed). It was a non-means tested grant after all and at the time universal wholesale maintenance grants were still in the memory of most people working in HE.
The reality of course was that this rarely occurred. There was one highly organised student that I was aware of that was hiring and firing her own support workers but I believe she was also doing this for her daily living support arrangements before she had arrived at university. Also, there was very little support in place anywhere so there was no market from which to choose providers.
As I understand it the monies are still supposed to belong to the student. This is part of the reason for continued government rhetoric around student choice in the DSA system. It was meant to be a system which gave students control over the services which they required.
But what’s the reality? There is no real choice in the provision of DSA. The way that the DSA will be spent is pretty much tied up by the assessment of needs (AoN) report. Whilst there is a quotation system built into the AoN process to ensure value for money, the student is not given a choice of who will supply any elements. The suppliers who are put in the AoN reports are decided upon by the assessment centres and more recently for NMH by the DSA-QAG database. The student is then told by SFE which supplier has been chosen i.e. the cheapest. In theory the student is allowed to swap suppliers but why would they do this? The process of applying for DSA is so complicated that by this stage most students are beyond the point of caring. And if it was really their money they would shop around; but at no stage does a student see the money nor are they given the real role of being a consumer.
Recently, when students have exercised their choice by switching suppliers to in-house provision or university-preferred suppliers, missives have been disseminated by SFE suppressing the practice. As if there is some kind of underhand activity going on. Various bureaucratic barriers have been put in place to stop this happening which makes a mockery of the notion of student choice. The idea being that the market should be left to create its own fairness through the invisible hand – but of course the market is missing an essential element – a ‘real’ customer. So it’s a false market. In one sense the market is working by creating ‘value’ because prices seem to be falling but not because of laissez-faire policies: rather through a much more deterministic two quote system.
Importantly, we shouldn’t forget that students make their choice when they apply for HE study through UCAS. They choose a university based on several criteria including the disability support available. When a student gets books from the library they are not expecting to pay for those services separately. Nor do they get to take their monies and buy their IT services from different places. So why should they be expected to shop around for their disability support? Especially when transition for disabled students is more complicated than for other students and any additional bureaucracy leads to additional barriers to access.
David Hopkins provided a useful summary of educational change approaches in an old (-ish) paper for the Generic Learning and Teaching Subject Network. In an attempt to ‘institutionalise’ inclusive teaching learning and assessment I developed a change initiative in an HEI I worked in recently, which had features built into it that went beyond implementation.
After a small working group was set up to review approaches to government changes to DSA funded support I realised that something much more embedded was required than just another short term task and finish group made up of the already converted.
Having seen many an initiative come and go with little long term impact I tried to utilise as many aspects of Hopkins’ suggestions as possible as changes to beliefs and values require much more than a few champions dotted around the university. And so the ‘Inclusive, learning and teaching framework’ (ILTAF) was born.
Based on previous attempts at ‘auditing’ institutional efforts around disability and equality, I produced a tool which was short and simple enough to ensure completion but complex and broad enough to ensure that some depth of thought was required for departments to complete it. But here’s the rub: the process of filling out the framework (after feedback I stayed away from the dreaded ‘a’ word) had to be built into high level committee structures, sanctioned by high level managers and required an ongoing commitment to embed change.
How was this achieved?
- Persistence – a number of years of change initiatives (HEA change programme; embedding inclusion into PGCert route; membership of an assessment working group in which inclusive practice was discussed).
- Consultation – the framework went through every possible committee available which had some link to student experience and/or teaching and learning. And changes incorporated into the design of the tool.
- Attention to change theory – I wrote an earlier post on Fullan’s work and Hopkins’ paper provides further guidance.
- Innovative tool design. The framework covers many aspects of teaching, learning, assessment and quality assurance. It is also self-rating so academic staff take ownership and do not feel threatened by outside judgement. It would have been pointless getting central services to ‘audit’ current practice.
The framework also worked on all levels of policy implementation as recommended by Fullan for educational change initiatives:
- Ratified by senior management: TOP DOWN
- Academic managers were given responsibility for completion and return of the framework by a deadline. They completed the tool in consultation with course teams but importantly the tool was sent out by the Registrar’s department (not the disability office): MIDDLE OUT
- It is based on actual (not normative) practice: BOTTOM UP
Built into the tool is a scoring system – but a potential problem with the self-assessment is how honest would the departments were going to be (no one wants to create work for themselves or leave themselves open to negative criticism). However, these anxieties were countered by requiring departments to give examples and provide case studies of areas in which they scored themselves the highest grade i.e. a 4 or a 5. And departments were given the responsibility of feeding this practice back to other departments. In this way internal expertise was developed and disseminated from within academic departments. We also developed webpages to support initial thought processes and it was intended to populate these pages with case studies and examples of practice. A national conference was also organised.
If departments scored themselves 3 or under they were required to develop an action plan for the next 2 academic years for improvement.
The tool needed to be completed again after those two years so that upward growth and improvement could be achieved. Changes would be made to the ranking system so that the achievement of the highest scoring became more challenging. It was also intended that students would fill out the framework after the first round to provide the student voice and to compare student experience with academic practice.
The Rose report (2009) drew together opinions from across the education debate to produce an informed direction for supporting dyslexia in the schools’ sector. Rarely discussed in HE circles, the report has many useful ideas to consider relating to the organisation of support.
It defines dyslexia:
- as a difficulty in learning accurate and fluent word reading and spelling, underpinned by problems with phonological awareness, verbal memory and verbal processing speeds. Phonological awareness approaches to assist learners to improve reading are certainly a key focus of recent approaches in the UK such as those promoted by Maggie Snowling and others, but it’s very unlikely that this is something covered in 1-2-1 specialist tuition session in HE.
- as a continuum, not a distinct category i.e. there are different levels of severity. By implication assessing someone ‘with’ dyslexia is a complex decision-making process. This an important point to consider for HE as the model is very much about a black and white distinction between someone being given the label of dyslexic vs non-dyslexic. In order to get DSA for example, the student needs to prove they are disabled i.e. dyslexic. This approach is problematic for a number of reasons – many HEIs have taken this distinction as a means for deciding who can access exam arrangements and what arrangement should be put in place but Rose suggests that there is no sharp dividing line.
- co-occurring – but these are not on their own markers of dyslexia, because there are a range of overlapping difficulties. For example, it is often suggested that organisational skills might be affected in students with dyslexia, but recent definitions such as in the Rose report suggest that phonological processing is the defining problem. It could be inferred that phonological processing difficulties and verbal memory might interfere with effective planning, but poor organisation is not of itself defining of dyslexia.
Early identification is also emphasised in the Rose report but it is still the case that a large number of students with dyslexia only get formally assessed when they enter HE. I’d estimate anecdotally the rate to be about 20-30%. This could be because they are able to survive at earlier levels of education, but as the level of literacy required gets more and more complex, problems become more acute. However, the story which many students relay, is that there was little support available.
A related problem about finding information on support available at university is also reported. A recent investigation undertaken by postgraduate psychology students at York University demonstrated further barriers which bureaucratic systems of policy implementation create within the sector. For example, whilst many HEPs insist on a post-16 educational psychologist’s report for exam adjustments a number of them don’t offer any support with paying for the report and some have even recently reduced the financial help available.
Glad to see colleagues from across the sector at yesterday’s training event run by Understanding ModernGov – HEinFE, HEIs, alternative providers etc. Broad range of topics discussed and debated. Interesting input from all presenters; legal, policy, models of support. Useful to re-visit some of the legal aspects the approach taken at De Montfort (which is flagged as an example of good practice) where several work streams are being taken forward – many of which are evident in a range of HEPs – so very positive to see. Some providers have opted out of DSA-QAG audit for NMH support. Notably Cambridge and Imperial but of interest today were a couple of ‘less well resourced’ HEPs opting out because of pragmatic reasons: not least the bureaucratic burden this places on already stretched resources.
The notion of complexity of support needs was mentioned again as it is in the recent Welsh Government commissioned report especially in reference to dyslexia. As I understand it the line which DfE/SLC (in HE that is) have taken is that dyslexia is a disability for DSA purposes and as they are following the Equality Act 2010 then the logical conclusion might be that it is a disability. However, it could be political expediency because of the DSA context and debates there have been recently within the sector. It doesn’t look like that’s the case in the schools sector: you could be dyslexic but not considered disabled because the support required is not ‘complex’ enough and/or your SpLD is ‘mild’. Not sure where the case law is on this but it would be interesting to see in terms of the debate around reasonable adjustments.
Also discussions about at what point the provider is legally obligated to provide reasonable adjustments for someone without the necessary paperwork to indicate an impairment. Anticipatory adjustments (such as inclusive teaching practice) should be in place. The potential for providers to pay for assessment/diagnosis (I use this term but apparently there doesn’t have to be a ‘diagnosis’ rather the emphasis is on the impact of a physical or mental impairment) as a reasonable adjustments was also suggested since legally providers are not allowed to charge for a reasonable adjustment.
Most HEPs are referring out to diagnosticians such as GPs and educational psychologists and providing financial help with paying for this, so whether this is seen as illegal is open to question. But then the idea of whether the provider could insist on paperwork was discussed. Taking a reasonable approach was mentioned. So with some learners it is very evident that there is an impairment but when 100+ students a year are walking in and saying they ‘think they might be dyslexic’ for instance; is it reasonable to put in place a DSA-equivalent support package until you find out for definite? If you can provide some level of support until you can get a clearer picture this may prove reasonable (perhaps!). Greg Boone from the Department for Education did say that re-assessment for SpLD students who are already diagnosed pre-16 was being reviewed. See this BBC story for more on this.
One of the policy instruments which complicates the picture in HE of course, is that reasonableness is partly based on other funding which is available, namely DSA for UK students. So in those cases it would likely be reasonable that you ask the students to make a claim for DSA at which stage they would need to provide confirmation of impairment to SFE/SLC. It is unlikely to be seen as reasonable that you provide a DSA-equivalent package for students who are eligible for, but refuse to apply for DSA.
Employment case law suggests that many cases are thrown out because a disability cannot be established so this is something which clearly is a contentious area and SLC now insist on paperwork which definitely establishes impairment as defined by the Equality Act before DSA will be disbursed – therefore not sure why that wouldn’t be the case for an HEP – i.e. not putting support in place until an EA2010 defined impairment is established. But it was suggested that SLC might be acting illegally*. As usual, in the area of disability and HE, there is very little case law to rely on to guide the sector and policy guidance is ambiguous (ECU guidance suggests that finances may not be an excuse for HEPs given the overall resources which are available but advice today seemed to suggest that it depends – on how big a provider you are and what else you have been doing in relation to support for disabled students).
*As a postscript to this, I read this morning in an archived NADP jiscmail posting, that SFE’s emphasis is now on demonstrating impact and for some students that have previous paperwork they might ask them to get more recent information that demonstrates impact. Which is in line with the Equality Act 2010.