A recent briefing ‘Moving beyond the bare minimum’ published by the Office for Students (OfS), asks whether universities and colleges in the UK are doing enough to support disabled students. The title of the briefing is perhaps somewhat unfortunate since, as the author points out, considerable progress has already been made in the last 20+ years in terms of improving access and one might be forgiven for thinking that the briefing could utilise a more accurate baseline with which to stretch the sector than the ‘bare minimum’. Here are a set of alternative observations based on the recommendations and arguments within the briefing, which are aimed at moving us ‘beyond the quite significant efforts’ that most institutions have already made:
- Most HEP corporate strategies envisage inclusive institutions, with senior management committed to inclusive practice and culture. However, the briefing does not give a clear vision for where the sector should be at this point in time (25 years on since the Disability Discrimination Act 1995 was implemented and nearly 20 years since HE in the UK was fully incorporated into that legislation). One way of evaluating this is to survey HEPs against the base level-document which was commissioned 20 years ago (failing that, use one of the previous Quality Assurance Agency’s code of practice). Instead of analysing access statements into which disability offices and disabled students often have very little input, the OfS should make it a requirement that, in the first instance, HEPs ensure they have ‘base-level’ suggestions in place.
- The briefing argues for more institution-wide schemes such as widespread use of recording of large lectures. Many larger and more established HEPs have made significant strides in this direction (albeit not with disability equality primarily in mind). However, projects such as this often require a significant injection of funding. The OfS could provide targeted funding for projects, outlining a range of areas which could be funded (so that HEPs who are ahead of the curve on this adjustment to practice don’t miss out). This could be considered when the OfS reviews the use of the £40M funding (Annex A at the bottom of this webpage) which they allocate to HEPs which is supposed to be aimed at disability specific provision. What usually happens is that the £40M allocated funding gets amalgamated into existing budgets (often the existing spending is far higher than the OfS allocation) and there is little incentive or ability to commit large additional pots of funding.
- Organisations such as the OfS need to move beyond the bare minimum in terms of social model thinking. Recent policy documents, including this OfS briefing, use the rhetoric of the social model of disability (particularly since changes were made to DSAs funding) but there has been very little movement beyond the bare minimum in terms of governance and policy instruments. We see this reflected in the briefing in the statistics which are presented, which are all based on medical impairment categories. I’m not convinced that a step forward is to ask HESA to split the ‘multiple disabilities’ (sic) category into its constituent parts. Anyone who has worked in disability services will tell you of the number of times when they’ve been asked by staff to give them a further breakdown of students’ impairments beyond the top line category. For example, when I first worked in HE academic staff wanted to know what each medical condition was and how it affected the individual’s learning – but why does a more in depth medical description of ‘von Willebrand disease’ for example, assist in delivering inclusive teaching and learning? More recently people have asked for breakdowns of specific learning difficulties category, and very recently, breakdowns of mental health difficulties disclosures. Again, the question is how does this assist in delivering inclusive teaching and learning? If we really want to move forward with understanding what HEPs are doing in terms of breaking down barriers we need to start gathering evidence on what adjustments are being made. We should be asking more social model related questions of providers such as how many people get extra time in examinations in each HEP? What percentage of lectures are recorded and put online? How much of the estates budget has been utilised to make buildings accessible in each HEP? The OfS should ask HEPs to start counting adjustments that they make to improve access (for example the numbers of examination alterations such as extra time) alongside the requirements to count student impairments. Best practice – the Open University support statistics on summer school adjustments.
- Non-continuation rates should be explored in more depth – without talking to people who have dropped out it is difficult to extrapolate what the reasons for the differential rates are. There will, no doubt, be a complex interplay between barriers in the environment and individual differences in the circumstances of the student. As the briefing points out some groups of disabled students do better than others. We therefore need to understand better why this is the case by (as the briefing suggests) exploring the experience of individual students. On a related point the briefing suggests that non-disclosure rates are an issue (but why is this an issue if the figures are at record levels and at record ratios?) We need to explore the story behind the data such as who’s not disclosing and why? Are people disclosing who aren’t disabled under the Equalities Act (DSA applications would suggest that this is the case since many get rejected because of a lack of medical evidence). We need to understand better and ensure that statistics are robust, before basing policy on them.
- Self-disclosure, as any HE disability office worker will tell you, grows rapidly as the academic year progresses, not least because the HE sector is running to a different beat to the rest of the education sector. Therefore, the OfS should pressure the government to remove the unnecessary barrier of replacing Education Health and Care Plans (EHCPs) at HE level. In the briefing an example of good practice is given of a college which helps disabled learners with transition. This transition planning would be greatly assisted if the funding systems weren’t so different between the different levels of the education system and if EHCPs weren’t replaced by assessments of need. The briefing mentions that there is cross political party agreement on this. In an accompanying document Piers Wilkinson points out disabled students face added burdens of arranging a number of additional matters, such as in-class support, when they get into higher education. This wouldn’t be as much of a burden if disabled students kept their EHCPs and if they didn’t have to negotiate a whole new and highly complex funding system when they enter HE.
- The OfS should think twice before offering any more policy and pressure HEPs to implement existing policies– in my study of policy implementation in HE there were over 300 policies which staff were expected to follow (a policy epidemic as Levin pointed out in 1998). We have had and continue to have, fit for purpose policy in this area; we had the QAA code of practice for 20 years; we’ve has the base level document around for nearly 30 years; and we’ve had the Equalities Act for nearly 25 years. Perhaps we can move beyond the bare minimum of much of the policy rhetoric and implement the policies which are already in existence?