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Executive summary


1. This consultation seeks views regarding the operation of student number control (SNC) flexibility from 2014-15 onwards, the entry of publicly funded providers of higher education not currently in a relationship with HEFCE into the student number control system, and changes to the high-grades policy to exempt a limited number of combinations of qualification types from the student number control.

2. The consultation will be of interest to providers of higher and further education, their representative bodies, other sector bodies, awarding bodies for qualifications, schools and schools associations, and students’ unions. We would also welcome comments from students, parents and anyone else with an interest in higher education in England.


3. This consultation has been developed in the context of the Government’s reforms to the funding and regulation of higher education in England. The 2011 White Paper ‘Students at the Heart of the System’ set out the Government’s vision for a more diverse, dynamic higher education system that would support student choice and encourage greater competition between providers of higher education, while ensuring that the demands on the student support budget remained sustainable.

4. Each year HEFCE sets each institution that it funds an SNC allocation for the number of publicly funded students it may recruit. The purpose of the student number control is to help manage government expenditure on higher education while also being implemented in a way that furthers the Government’s ambition to improve student choice and to enable popular institutions to respond and expand. It has therefore decided that some students are not counted against the control. Universities and colleges may therefore recruit outside their student number control allocation as many students with high grades (as broadly defined by Government) at A-level and certain equivalent qualifications, as they are able to. HEFCE refers to this as the ‘high-grades’ policy. In 2013-14, the threshold for exemptions from the SNC under this policy includes students with grades of ABB or higher at A-level or certain equivalent qualifications.

5. The January 2013 grant letter from the Department for Business, Innovation and Skills (BIS) to HEFCE noted that for 2013-14 there was capacity to apply student number controls less rigidly. HEFCE has been asked to give institutions some flexibility to recruit above their SNC allocation without incurring a grant reduction. For 2013-14 this flexibility equates to 3 per cent of an institutions’ total HEFCE-fundable recruitment in 2012-13. We informed institutions of this in January 2013. In addition, the Minister for Universities and Science asked us to consider ‘increasing recruitment flexibility further in 2014-15 for those institutions that show strong recruitment patterns, and to treat those institutions enjoying less demand less favourably’1.

6. A number of schools and other organisations have expressed concern to HEFCE regarding the fairness of the operation of the high-grades policy. The current exemptions list (which details the qualifications and grades a student must have to be exempted from the student number control) does not include any combinations of different qualification types (for example students holding an A-level and BTEC qualifications). Neither are EU qualifications exempt, nor allowances made within the exemptions list for the use of contextual data.  However, there are various mechanisms within the way the SNC currently works (and which will continue to apply in future) that seek to ensure institutions have sufficient numbers to make autonomous admissions decisions that maintain fair access for all students.

Key points

Student number control flexibility

7. We propose a mechanism where any institution that recruits above its student number control allocation, but within the limit of the flexibility provided, should receive an increase to its future allocation and continue to benefit from flexibility.

8. As we have not been asked by the Government to increase the number of places available to the sector, increasing places to others can only be achieved by reducing the allocations to institutions who recruit significantly below their student number control allocation. We propose that for these institutions, while their allocation will be reduced, we may be able to offer some additional flexibility in the following year as an opportunity to recover.  Overall, as the Government have placed a clear emphasis on the importance of student choice, it is not in the interest of students, or institutions who may have unmet demand, that places remain with institutions that are unable or unwilling to fill them. 

9. The workings of the flexibility mechanism depend upon affordability; this in turn depends upon recruitment levels from the controlled population and of students exempt from the student number control. The flexibility, increases to SNC allocations, and opportunities to recover will need to be determined on an annual basis in the light of the recruitment levels across the sector and the perceived risk to the Government’s higher education budgets.

10. Institutions that recruit at a level above the flexibility permitted will be subject to future grant reductions, and will be expected to offset that recruitment in future years. They will not receive an increase greater than that which would have been offered had they recruited within the flexibility range. 

Publicly funded providers of higher education that do not currently have a relationship with HEFCE

11. Some publicly funded providers of higher education (predominantly further education colleges) that are not currently in a direct funding relationship with HEFCE may have students who currently claim student support. We propose how we might facilitate the entry of these publicly funded providers into the student number control system. In the case of providers that currently have students receiving student support, an SNC allocation equivalent to their existing number of students should not represent an increase in the number of students eligible to claim student support, and we will be implementing this for 2014-15.

12. For any publicly funded providers that do not currently have students that receive student support, who wish to enter the system, we propose that this could be facilitated either through a bidding process, or through an allocation of a set number of places for 2015-16. We explore how we could redistribute numbers within the sector in order to accommodate these providers, without there being a net increase in the number of places available to the sector. We propose that this could occur by utilising numbers released through either the flexibility mechanism or a pro-rata reduction for all other providers. 

Expanding the qualifications exempted from student number controls by the high grades policy at the threshold of ABB or equivalent

13. The Government has asked HEFCE to consider whether there is scope to expand the uncontrolled population in 2014-15, by extending the qualifications exempted by the high-grades policy at the threshold of ABB or equivalent to further support student choice.

14. The current approach to implementing the high-grades policy aims to balance a number of priorities: the need to predict and control the demand on a limited student support budget; the need to keep mechanisms relatively straightforward for providers and students; and the need to ensure that outcomes for all applicants are fair.

15. We therefore propose that any approach we take to extend the exemptions list should meet the following requirements:

  • be workable
  • be guided by the principle of fair admissions
  • minimise the risk of unplanned student support costs, or costs that exceed the budget.

16. We considered a number of proposals against these requirements. Changes to the system may have unintended or undesirable consequences for the complexity of implementation, and the need to understand and manage the financial exposure of the student support budget and need to be evaluated carefully. Our proposals aim to minimise the risk of undesirable consequences.

17. For any exemptions it is vital that we are able to make a reasonable estimate of the number of people who become exempt from student number controls and their propensity to enter higher education; we consider that by some way the most proportionate and effective way to do this will be to exempt a limited number of combinations of qualification types from the control. Our preferred proposal is one in which we exempt a limited number of combinations against set criteria.

18. We propose the following criteria:

  1. The combination of qualification types comprises A-level and one other qualification type which is present on the HEFCE exemptions list (for example, a BTEC subsidiary diploma and two A-levels). We would include the most favourable combination of one or two A-levels with one other qualification type, that amounted to a total size equivalent to no more than three A-levels.
  2. The combination of qualifications is reported and present in the most recent data for setting student number controls.
  3. We are able to list these formally, in terms of qualifications and grades exempted, to ensure the approach can be implemented by institutions and HEFCE. This means any qualification included in a combination must be one for which grades are awarded.
  4. Any combination of qualification types should reach a threshold of 100 students who would become exempt across the monitored population in the most recent available data (and who must also meet criteria a, b and c). 

19. Based on modelling using the most recent data that we have available, we believe that this would exempt five combinations of qualification types from the student number control in 2014-15, representing approximately 4,000 students.

Responding to this consultation

20. The closing date for responses is 1700 on Friday 28 June 2013. Responses should be made using the online form that accompanies this consultation on the HEFCE web-site.

Date: 3 May 2013

Ref: 2013/10

To: Heads of HEFCE-funded further education colleges, Heads of HEFCE-funded higher education institutions
Heads of schools and school associations, Qualification Awarding Bodies

Of interest to those
responsible for:

Senior Management, Admissions, Planning, Finance

Enquiries should be directed to:

HEFCE-funded colleges and universities should raise any questions with their HEFCE institutional team (see searchable list of contacts).

Queries from other interested parties should be sent to