A focus on… Consultations

The UK Parliament’s Autism Act 2009 Committee launched a call for evidence to gather insights on how autism policies and support services are working in practice.

They sought input from autistic people, their families, carers, professionals, and researchers on areas including public understanding, assessment and diagnosis, healthcare, education, employment, community support, and interactions with the justice system. The aim is to inform the Committee’s recommendations to improve autism support across the UK.

Click here to view the EPC’s full response.

The House of Lords Science and Technology Committee consulted on how the UK can better finance and scale science and technology, given persistent challenges in translating R&D strength into economic growth. They sought input on barriers to scaling companies, international comparisons, and the effectiveness of government decision-making and coordination in S&T strategy. The inquiry also asked about the roles of public and private sector investment, including late-stage investors and capital markets. Finally, they explored policy levers, such as procurement, that could help bridge the “Valley of Death” and support UK innovation to deliver societal and economic benefits.

Click here to read the EPC’s response.

The EPC responded to this consultation highlighting that engineering is a strategically critical subject and a key driver of economic growth, with engineering accounting for nearly a third of the entire value of the economy. It drives key government mission and opportunity, including the new industrial strategy, and is a powerhouse of regional development as it is spread remarkably evenly throughout the country.

Engineering is at the financial sharp end of the inquiry’s focus. A structural £8k annual underfunding per domestic undergraduate student means that expanding student numbers does not help dilute fixed costs. Instead, each additional home engineering student deepening the deficit, as losses increase as enrolment rises. Providers are mitigating this phenomenon by actively flatlining recruitment in a buoyant applicant market.

Within the current funding model, international student fees operate as the only viable cross-subsidy. International student recruitment is already critical to balancing budgets, without which Engineering programmes are essentially insolvent. Any disruption to international enrolments risks destabilising engineering faculty finances and could precipitate insolvency at departmental or provider level. Adding the proposed Government six per cent international tuition fee levy would be unworkable and OfS’s forecast to improve sector finances with overseas recruitment is overambitious.

Government policy should recognise international engineering students as strategic assets. International engineering students are a critical part of the UK’s future skilled workforce. Restricting this talent pipeline via visa constraints undermines national industrial and innovation strategies.

There is now an urgent need for realignment of funding to actual course delivery costs and to enhance and sustain international student pipelines (including by resisting visa cost increases).

See here for details.

The role of the UK’s innovation ecosystem in achieving the Government’s mission to kickstart economic growth across the country is dependant upon Engineering higher education (HE). We outlined how universities and businesses work together to commercialise research and to tackle obstacles such as funding and market access. We also considered the role of structural factors—such as the tax system, regulatory requirements, and standards—in influencing the success of start-ups, spin-outs, and other innovation-focused enterprises. Finally, the link between innovation and economic growth both regionally and nationally, highlighted lessons from international comparators and considered the impact of regional clusters and hubs, including the Catapult network.

Universities play a pivotal role in a healthy and thriving innovation ecosystem. They are essential for a successful transition of research into industry and for regional growth and economic development.  The role of universities as drivers for growth is well documented. Many universities are place-based anchor institutions, critical to the sustainability and growth of their whole region. While significant investments have been made in research and development (R&D), there are more opportunities to enhance these efforts further, ensuring that they are more inclusive and supportive of regional diversity.

The EPC identified a number of challenges that are limiting regional development:

• Balancing investment between established excellence and supporting growth.
• Uneven regional distribution
• Attracting and retaining local and global talent
• An insufficiently modernised engineering curriculum
• Limited collaboration between universities, business and local government

See here for details.

The DfE sought views from stakeholders to share their perspective on potential improvements to the curriculum and assessment system. The call for evidence invites stakeholders to submit proposals on improving the curriculum and assessment system.

See here for details.

To help shape the vision and principles of the Engineers 2030 project, the National Engineering Policy Centre conducted a consultation from March to July 2024, which welcomed contributions from all parts of the engineering community and beyond.

In response, Engineers Without Borders UK and the Engineering Professors Council collaborated closely to develop a unified response drawn from public engagements and written feedback from over 75 individuals in our communities. This collective approach has allowed us to integrate the expertise and insights from both organisations and ensure our recommendations are more impactful.

Additionally, we provided feedback on critical aspects such as timelines for change and “day-in-the-life” narratives from the visioning workshops, enriching the consultation with more practical and forward-looking insights.

Summary and recommendations
Our response identifies six areas for improvement:

• Strengthen the vision by making it more concise and bolder
• Reframe the principles to be ‘qualities’ of engineers / technicians
• Strengthen the focus on global responsibility in engineering
• Prioritise upskilling / reskilling the current workforce
• Prioritise systems change in higher and further education
• Be more action-oriented by connecting with existing change efforts.

See here for details.

The Education Committee has launched an inquiry to examine the changes in numbers of international students in recent years, the impact of international students on university funding and availability of places for domestic students, and whether universities are achieving an appropriate balance between international and domestic students.

We submitted evidence in response to concerns over government policy in relation to international students upon whom HE engineering, the engineering workforce, and the UK economy depends. The EPC expressed serious concerns about the impact of migration policy on the future of engineering in higher education (HE) and the wider impact on society through research, innovation, skills shortages and economic impact. As, the student and graduate visa route is of critical importance to the engineering sector, we urged the retention of the vital Graduate Visa Route, without which the sector will be unviable in its current form.

See here for details.

The EPC has responded to the OfS consultation on the approach to public grant funding. We have urged that additional funding is needed to support Engineering courses and departments, based on the following factors:

• Engineering is critical to the success of the UK economy.
• Engineering HE could not be more strategically important.
• Engineering requires more specialist, and thus expensive, teaching and learning facilities and equipment
• This essential resource is easy to lose, but once scaled down, scaling back up in Engineering is not possible without extensive investment.
• The average course funding deficit for each STEM student is double that across classroom-based subjects.
• There is concern that necessary teaching and learning innovations are isolated due to the lack of discipline-specific educational development funds.
• Engineering relies hugely on cross-subsidy from international students.

See here for details.

The Institute of Apprenticeships and Technical Education consulted on how the employer stamp of approval should be granted to qualifications funded through the Lifelong Learning Entitlement (LLE), seeking input on how to ensure LLE and modular design ensures high quality, relevant and flexible qualifications.

The EPC collaborated with the Engineering Council on a response to urge IfATE to work with professional, statutory and regulatory bodies, to ensure that qualification align with the standards set by those bodies on behalf of professions.

See here for details.

The Department for Education (DfE) has proposed far reaching reform of A levels and T levels and a cull of other level 3 qualifications. A proposed Baccalaureate-style qualification framework for 16 to 19 year-olds, the Advanced British Standard (ABS) offers greater breadth to 16-19 education than existing level 3 qualifications. More information on the proposals can be found in this EPC explainer.

The EPC joined a National Engineering Policy Centre (NEPC) taskforce including Engineering UK, the Royal Academy of Engineering and the Engineering Council to lead on an Engineering sector response. We led and sought EAN member feedback on the elements relating specifically to grading and assessment. The NEPC response to which we were key contibutors is here.

A more detailed EPC response was made using the DfE easy read service. You can view the EPC response here.

Our key messages were:

• A wider curriculum to 18 is welcome.
• The continued division of academic and technical routes perpetuates the longstanding binary academic and technical divide.
• Reforms may particularly disadvantage those providers who support the very students this proposal has at its heart.
• Resolving the teacher crisis is a critical dependency to the success of this initiative.
• To limit and curtail qualification choice at level 3, the DfE must satisfy itself and the sector that other level 3 qualifications, such as BTECs, do not serve an important purpose which will be lost in implementation of the ABS.
• A future-proof education system must recognise the importance of personal attributes that ensure our next generation is work ready.
• We welcome greater Engineering’s presence in the curriculum, but urge that government works with HE providers and subject experts to ensure that a single subject approach is fit for purpose and supports progression.
• A broader base and higher quantity of Maths at level 3 is welcomed in Engineering but we have reservations about making it compulsory.
• There is a valuable opportunity here to decompartmentalise the curriculum to harness the golden threads of education and join up all components within a unified approach.
• There is a crucial need and opportunity to look radically at the way we view and implement assessment at level 3.
• A single grade for the ABS would be highly reductive and unhelpful. It would risk raising the stakes without adding value.
• Consultation thinking around pathways to HE is notably under-developed. University involvement in the formation of the ABS is essential.
• It is problematic that the scope of the Advance British Standard extends only to England. No mention is made of how this will be managed within a UK system.

See here for details.

The Lifelong Loan Entitlement (LLE) – enabling student loan support for individual modules – will be introduced for the 2025-26 academic year. In preparation for this change the OfS asked the sector for evidence to inform its thinking on how to regulate the LLE. As long as it aligns with their general approach to regulation; so, how will the B3 outcomes measures of “continuation”, “completion”, and “progression” work for short courses? These become more tricky if the policy trajectory for students to study, train, retrain and upskill – possibly part-time and across multiple subjects and providers – throughout their lives rather than pursue complete qualifications comes to fruition.

The OfS has committed to a formal sector consultation in 2024, so the EPC has not submitted evidence at this stage, in consideration that:

• Most modular provision at levels 4 to 6 (other than HTQs) would not move into LLE scope until 2027–28.
• Demand for (and the possible impact of) LLE-style provision has not been well researched. We do not have any evidence of risks or opportunities to engineering as a result of funding at a modular level.
• Our members did not share views with us on this subject yet. We are keen to get a better understanding of our members position on this during the Access and Admissions Forum in December in advance of the OfS consultation in 2024.

We are minded that:

• In our response to the consultation on regulating student outcomes we highlighted that the measures of quality (student outcomes) proposed by OfS had not taken adequate consideration of the LLE.
• The B3 positive outcomes are unsurprisingly inappropriate for the change in delivery of HE courses to modular provision. The OfS indicated in Jan 2022 that they would review their approach in light of LLE implementation; it is disappointing that OfS is now simply asks the sector how to fit modular qualifications into a regulatory framework ill-designed to accommodate them.
• OfS’s approach is a concern in relation to regulation hierarchy – specifically for high-cost subjects; burden on providers; workload and impact on students; and – in engineering especially – the onward impact of international standing.
• The alignment with accreditation is a complicating factor in engineering as there may be a disconnect between what qualification content might properly belong at different levels and what level of learning outcome might be expected. To comply with international standards, full-time accredited degree courses are unlikely to be broken up into stand-alone full-time modules, or to facilitate cross-provider attendance.
• Engineering could potentially benefit from subject changeability through the adoption of try-before-you buy engineering modules at levels 4 and 5 as alternative routes to level 6 which would serve to introduce the subject which is largely not taught in schools. This could include study across more than one provider but mobility (of the part-time and mature students this is likely to appeal to) is likely to be seriously limited in most city and all rural areas.

See here for details.

The EPC responsed to the Office for Students (OfS) is consultation on the introduction of a separate “split indicator” for higher technical qualifications (HTQs) to enable the regulation of student outcomes. HTQs are L4 and 5 HE qualifications linked to occupational standards approved by the Institute for Apprenticeships and Technical Education (IfATE). They can include existing higher national certificates (HNCs), higher national diplomas (HNDs) and foundation degrees, but these qualifications are not necessarily approved as HTQs. The first engineering HTQs were approved in 2022 as part of the third tranche of subjects to be onboarded.

Split indicators are used by OfS, providers, Government and others with an interest in HE outcomes to measure performance of student cohorts – against minimum thresholds – by mode and level of study, subject and student characteristics.

The introduction of a split indicator for HTQs will decouple student outcomes measures for Level 4 and 5 HTQ qualifications from ‘other undergraduate’ with a view to establishing these courses as a distinct type of higher education. The Government also wants to demonstrate the benefit to taxpayers of giving students on these courses early access to the lifelong loan entitlement or additional funding or benefits in future.

Key messages

• 1. As it is not proposed to establish HTQs as a level of study, performance data for these courses cannot be split by subject, which renders the data unhelpful. Although the OfS signal that they will review this again following an increase in student numbers, there is not currently evidence of demand or additional supply.
• 2. With existing qualifications, such as Foundation degrees, sometimes being badged as HTQs and sometimes not, it is unclear to both the EPC, and presumably to students, what exactly would be covered by the HTQ split indicator and what remains in other undergraduate. Additional transparency is needed here.
• 3. OfS’s approach is a concern in relation to regulation hierarchy, specifically for high-cost subjects; including burden on providers; workload and impact on students. The proposal to introduce split indicators for HTQs will introduce up to nine additional data cuts for each provider on the proportion of students who continue with their studies, complete their studies and go onto professional employment, further study or other positive outcomes. This is an additional burden.
• In engineering, overregulation and disregard for existing regulation frameworks has an onward negative impact of UK engineering’s international standing. Engineering as a subject is already heavily regulated and HTQs are already effectively regulated by IfATE.
• We remain concerned that the partial exclusion of international students from metrics is likely to lead to an incomplete and potentially inconsistent picture, while the employability of engineering students on a global stage will lead to underrepresentation of performance. Approximately one in four students is international in Engineering; a higher proportion than in almost any other discipline.
• We continue to urge OfS to adopt criteria for success that better recognise the distance travelled in terms of achievement for students who reach degree standard from a lower base of prior attainment and in the face of greater challenges.

See here for details.

n June 2023, the four UK higher education funding bodies published key decisions on the high-level design of the next research assessment exercise. The EPC’s Research, Innovation and Knowledge Transfer Committee responded to the Jisc consultation which informed these decisions; the initial consultation and EPC response are available here.

The EPC’s Education, Employability and Skills Committee responded to The Department for Education (DfE) position on generative AI in and subsequent call for evidence. This was informed by a full member consultation – led by Manish Malik (Canterbury Christ Church University) and Paul Greening (Coventry University) – to enable the EPC to draw together evidence from across the Engineering Academics Network and to remind the DfE that universities are leading the way in the development of generative AI in education.

We highlighted evidence from the network of ways AI is used in Engineering higher education; the positive outcomes of greater use and sophistication of generative AI; ways in which the DfE could support the possibilities; and challenges that need efforts from all involved.

In summary

We would expect to see the following positive outcomes as a result of the greater use and sophistication of generative AI:

• An increase is productivity for staff and students, which would extend to the future workforce. This means companies would expect expert use of these systems and better outcomes from their employees. This will have implications for higher education institutions and lifelong learning circuits. For example, staff may use AI (Artificial Intelligence) for assessment work, may even automate viva and really take the role of ensuring the interactions between the learners and the systems are meaningful and the students are actually learning, by being the human in the loop.
• A beneficial effect of the above could be to improve Just, Equitable, Diverse and Inclusive practices in higher engineering education. For example, compassionate, relatable and accessible feedback, content and assessments.
• Support staff and students with better decision-making and better student outcomes (retention, progression, closing gaps etc) as Learning Analytics and AI come together.

DfE could support the investigation of the possibilities and positiveness of:

• An increase in personalised learning opportunities with AI chatbots and AI Tutors. Students in future may learn and be assessed in different settings than those they currently experience. Personalised tests may become more common, but care should be taken to ensure they are equitable and assess the learning outcomes for which the course is designed. Staff must play the human in loop role here to ensure this is what is happening.
• AI is increasingly present in many design tools as this may hinder the development of critical skills needed by engineers. If the engineers have full appreciation of the design, its underlying theories and limits of the tools, this should be encouraged. In fact, many virtual / simulation tools may become a useful source of data for AI systems to model human interactions with machines being modelled in these tools.
• An increase in supporting the development of self-, co- and shared regulation of learning with AI-led orchestration of individual, pair and small group dynamics and learning within engineering education. If AI is tapped into correctly, it will certainly add to what has been achieved and extend it to many other scenarios. Staff’s role here would be to set up such a system to do what they would normally focus on when orchestrating their class interactions etc, without the technology and instead do what the technology cannot do.

Challenges that need efforts from all involved:

• Ensuring data used in such systems is not bad data with bias.
• Data and privacy concerns and AI systems are secure, so they are not misused.
• Staff and students need to improve their awareness of what behaviours, skills and knowledge will be in demand for their current and future jobs, respectively.
• AI raises concerns about academic integrity, but these can be mitigated, as mentioned above, by AI assessing students multiple times and academics always acting as humans in the loop.
• Trusting such systems can be either too easy due to their magical feel or too difficult for many and something needs to be done to moderate both ends.
• Increasing chasm between Humanities and Technology proponents need to be bridged so the systems are more ethical, sustainable and understood both from the point of view of what is possible but also from the point of view of what is the consequence to society.

See here for details.