A blueprint for fair access?











This post reviews fair access developments subsequent to publication of the HE green paper and preceding publication of the impending white paper.

It asks whether some of the recommendations proffered by the Scottish Commission on Widening Access (COWA) should also be adopted in England.

Developments since the HE green paper

In England the green paper ‘Fulfilling our potential’ was published in November 2015 and a white paper is expected shortly.

The green paper reinforced two Tory targets announced during the election campaign, one to double participation amongst students from disadvantaged backgrounds compared with 2009 levels, the other to increase BME participation by 20% by 2020.

It proposed a seven-part action plan which is now being implemented:

  • New guidance to the Director of Fair Access on the progression and success of under-represented groups. This issued in February 2016, rapidly followed by Offa guidance to HEIs on 2017-18 access agreements.
  • A UCAS consultation on the feasibility of introducing ‘name-blind’ applications from September 2017. UCAS has committed to a two-stage consultation process: initial evidence gathering followed by a formal exercise inviting views on several options. The second stage has not yet begun and might be timed to coincide with the white paper. SPA published its own report on the evidence base in December 2015.
  • Inclusion of access metrics within the Teaching Excellence Framework. A technical consultation will presumably launch alongside the white paper. One might have expected the social mobility advisory group to inform the development of access metrics but it makes no reference to them. In February 2016 the Business, Innovation and Skills Committee published a report on the TEF which noted unintended consequences associated with some potential metrics. It recommended that the government should consult on its proposed metrics which would also be integrated into Offa’s access agreement methodology.
  • Establishment of an Office for Students to incorporate Offa functions which would be funded by subscriptions from HE providers. This is associated with wider efforts by BIS to drastically reduce operating expenditure, headcount and partner bodies, as confirmed in its single departmental plan for 2015-20.
  • Cross-departmental work to ‘address some of the root causes of inequality of access and outcomes for different groups in higher education’, including collaboration with DfE, to ‘…explore how we can further raise aspirations and attitudes in particular for white males from disadvantaged backgrounds’. There is nothing about this in the March 2016 education white paper ‘Educational Excellence Everywhere’. Perhaps there will be more in the Life Chances Strategy under development in DWP which, according to its single departmental plan, will ‘set out a comprehensive plan to fight disadvantage and extend opportunity so that every child can reach their full potential’.
  • Potentially a legal power to ‘require bodies providing a service connected with the provision of higher education to provide relevant data and informationto help better target efforts on widening access and success’. UCAS set out its own plans for data release, but argued that a legal power was ‘neither reasonable nor proportionate’. Then in January 2016 Prime Minister Cameron confirmed that a new transparency duty would be imposed on universities by legislation, requiring the publication of applications by subject, and of admissions and retention data by gender, ethnic and socio-economic class. This might or might not be restricted to ‘key disciplines’. UCAS was not mentioned.

There were signs that Number 10 judged this programme insufficiently ambitious. On 1 February the Prime Minister’s office, BIS and Offa convened  a summit ‘to help identify other ways forward’. No outcomes were confirmed, but a press release revealed that themes discussed included: data, cross-sectoral collaboration, innovative approaches to social mobility and action to speed up progress towards the two targets.

In March 2016 Hefce announced a new National Collaborative Outreach Programme funded from 2016-17 to 2019-20 to the tune of £30m in the first year and £60m in each succeeding year. Consortia of HE institutions, schools, colleges and other providers are invited to provide intensive outreach programmes in HE participation ‘coldspots’.

There is no obvious fair access dimension to this programme and it has subsequently been confirmed that central funding for the existing National Networks for Collaborative Outreach (NNCOs) – which do have a fair access agenda – will not continue beyond December 2016. It remains to be seen whether any of the NNCOs will survive.

Also in March 2016 the Government announced plans to develop new common national measures of socio-economic background to monitor social mobility. These could potentially be extended to HE admissions, so removing institutions’ discretion to adopt their own preferred measures subject to approval of their access agreements. But that possibility has not yet been mooted officially.


Scotland’s Commission on Widening Access

The Scottish Government’s 2014-15 programme for government ‘One Scotland’ (November 2014) included commitments to:

‘Begin work on a new target to close the equality gap in terms of university access and…set up a Commission on Widening Access to advise us on critical steps and milestones towards this goal.’

The target, or ‘long term goal’ as set out in the 2015-16 programme for government is that ‘20% of university entrants come from the most disadvantaged 20% of society’.

The Commission on Widening Access was established in spring 2015.

An initial press release (March 2015) announced the appointment of Ruth Silver as Chair. A subsequent notice (April 2015) confirmed the remaining members.

The Commission’s Remit was to:

  • ‘synthesise existing evidence around barriers to widening access and retention, and their effective removal, for those from deprived backgrounds and, within this, identify any specific barriers for those with different equality characteristics or those from a care background;
  • propose both a short and long-term target for participation in higher education and clear milestones, to drive further and faster progress to widen access;
  • identify best practice on widening access across early years, schools, colleges, universities and employers, and make recommendations as to how best practice on access and retention can be scaled up and embedded, within the work of individual institutions, across the wider education and employment system;
  • identify the data and information required to monitor and support improvements on widening access across all education providers, and recommend the processes necessary to support this.’

It was asked to ‘draw preliminary conclusions and recommendations’ in autumn 2015 and produce a final report by spring 2016.

The Commission published an analysis of responses to a call for evidence (June 2015) and an interim report (November 2015). The final report  issued in March 2016 together with an associated technical paper on measures and targets.

On 17 March First Minister Sturgeon warmly welcomed the report, saying that the government accepted the Commission’s recommended targets. It would give careful consideration to the other recommendations, with the intention of publishing a full response early in the next Parliament if re-elected.

By 23 March the government had also accepted another recommendation on the admission of students with experience of care. At the same time it announced a very marginal 0.1% improvement in 2014/2015 towards its overarching 20% target.

In April the SNP confirmed that its manifesto would commit to implementing all COWA recommendations directed at government and, further, would support  implementation of all COWA recommendations.

The announcement confirmed the SNP’s intention to appoint a Commissioner for Fair Access.

There was perhaps a hint of U-turning weasel wording in a blog post by Angela Constance, which confirmed commitment only to the overarching target and not the interim and supporting targets (see below). The SNP’s written manifesto commitment will need close scrutiny.


Key COWA recommendations

COWA proposed a series of targets for improving full-time first degree admissions to Scottish universities, which include:

  • Meeting the government’s overall target – students from the 20% most deprived backgrounds should represent 20% of HE entrants – by 2030.
  • Interim targets of 16% of entrants from such backgrounds by 2021 and 18% by 2026.
  • At least 10% of entrants to every university should be from the 20% most deprived backgrounds by 2021, this then to be reviewed in the light of progress.

The Commission’s definition of disadvantage is based on the Scottish Index of Multiple Deprivation (SIMD).

The technical paper reveals that it convened an expert working group which agreed that a basket of measures with three components – area deprivation, household income and school environment – would be preferable. However, the Commission concluded that the data available was insufficiently universal or reliable to support this.

The recommendations relating to students with experience of care include:

  • By 2017 all those who meet the access threshold (see below) should be entitled to a place at a Scottish university and
  • From AY2017/18 they should receive a non-repayable bursary in place of loans for living costs and ‘a more flexible package of student support’.

Further recommendations which remain under consideration by the government include:

  • By 2018, a new Commissioner for Fair Access, working with experts, should publish a Scottish Framework for Fair Access. This authoritative, evidence based framework should identify the most impactful forms of access activity at each stage of the learner journey, from early learning through to higher education and provide best practice guidelines on its delivery and evaluation.
  • Universities, colleges, local authorities, schools, SFC funded access programmes and early years providers should work together to deliver a coordinated approach to access which removes duplication and provides a coherent and comprehensive offer to learners.
  • By 2019 all universities should set access thresholds for all degree programmes against which learners from the most deprived backgrounds should be assessed. These access thresholds should be separate to standard entrance requirements and set as ambitiously as possible, at a level which accurately reflects the minimum academic standard and subject knowledge necessary to successfully complete a degree programme.
  • Universities, working with schools, should take greater responsibility for the development of the pool of applicants from disadvantaged backgrounds by delivering academically based programmes to support highly able learners, who are at risk of not fulfilling their academic potential.
  • The Scottish Government and the Scottish Funding Council, working with key stakeholders, should develop a consistent and robust set of measures to identify access students by 2018.

Clarifying the English targets: Disadvantaged

The green paper said that the target to double participation by disadvantaged students would involve increasing the participation rate from 13.6% in 2009 to 27.2% in 2020.

There has been some disagreement over whether the 2009 baseline is the entry rate for English 18 year-olds from POLAR2 or POLAR 3 Quintile 1. Assuming the more recent POLAR3 measure, the percentage had reached 17.8% by 2014 and 18.5% by 2015.

So there has been an improvement of 4.9 percentage points in six years but there is a further 8.7 percentage point gap to make up in the next five.

The 18.5% figure is equivalent to 24,300 entrants, whereas the target of 27.2% is equivalent to 32,000 entrants, so demanding an additional 7,700 disadvantaged entrants by 2020 and an annual increase of some 1,500 disadvantaged entrants.

Hefce calculates that the annual increase on current trends is closer to 900 entrants. It says that, whereas provisional UCAS data for 2016 suggests a 1.0 percentage point improvement compared with 2015, annual growth of around 2.0 percentage points is required to meet the target. Assuming current rates of improvement the target will not be met until 2027.

According to UUK, which has used POLAR2 Quintile 1 as the baseline, the current annual rate of increase is 1,000 and this has to increase to 1,400 per annum to meet the target.

The Social Market Foundation (SMF) has begun to draw out the implications of pursuing this strategy, though not very clearly.

The strong temptation will be to increase participation amongst the predominantly lower-tariff institutions that are already comparatively successful in recruiting disadvantaged students, rather than challenging the predominantly high-tariff institutions that have the least representative intakes.

The BIS guidance to Offa exhorts it to focus on the latter:

‘The ending of student number controls provides an opportunity for highly selective institutions to make progress and open their doors far more to students from disadvantaged backgrounds.

The Government accepts that selective institutions already do much to widen participation. We also acknowledge the work that they already do. Nonetheless, we are convinced that more could and should be done, and we look to you to push hard to see that more progress is made.’

But there is precious little follow through in Offa’s guidance to institutions on their 2017-18 access agreements. This merely says that the targets chime with the aim in Offa’s strategic plan to:

‘…make faster progress in improving access to the most selective higher education institutions by students from under-represented and disadvantaged groups.’

In presenting UCAS data it says higher tariff institutions should:

‘…consider how best to significantly scale up activity, and increase coverage to increase the rate of change.’

But that is it.


Clarifying the English targets: BME

There has been very limited analysis of the BME participation target for which there is no confirmed baseline. SMF projections use HESA data for all UK-domiciled undergraduate students, both first year and all years.

Even if the total student population is the correct measure, rather than the annual intake, the target must be England-specific.

My own previous analysis used figures from the Equality Challenge Unit’s 2015 report for all UK-domiciled BME students attending HE in England (2013-14).

This suggests a 20% increase would be equivalent to an additional 70,000 BME students compared with a 2013/14 baseline, the total reaching some 416,000 BME students by 2020.

As the IFS has shown, all BME groups are now, on average, significantly more likely to go to university than white British students. This is true of the overall populations and four of five socio-economic quintiles. In the case of the highest quintile, White British participation is higher than for black Caribbean and other black students, but lower than all other BME categories.

As I pointed out in my earlier Green Paper analysis, pursuit of a BME access target seems perverse given that the admission of white male disadvantaged students is a particular priority and BME issues at system level are confined largely to retention and outcomes.

This is implicitly recognised in the BIS guidance to Offa which highlights three specific target groups in these terms:

  • ‘access for young white males from disadvantaged backgrounds;
  • outcomes for students from black and minority ethnic backgrounds; and
  • access, retention and outcomes for students with specific learning difficulties or mental health needs’

These priorities are reinforced in Offa’s access agreement guidance.

UUK’s social mobility advisory group takes the same line:

‘In taking forward the prime minister’s goal for increasing the number of black and minority ethnic full-time undergraduates by 20% between 2014–15 and 2020–21, the group agreed that priority should be given to assessing the ways forward for removing differences in retention and outcomes for students from identified minority ethnic groups.’

Even the right-leaning Policy Exchange think tank has argued:

‘The government should abandon this target as non-white minority representation in universities is not really a problem, though there has been an issue with representation in the most prestigious universities for some groups. Instead, policy should be better targeted towards those for whom the rate of university going is lowest – namely white British students from the poorest socio-economic backgrounds…’

If Offa persists in enforcing progress at ‘the most prestigious institutions’ there is potential conflict here.

In achieving stronger BME representation these institutions may increase disparities in participation between:

  • Over-represented and under-represented BME groups
  • BME students and white students
  • Advantaged and disadvantaged students.

The Government would be wise to clarify its position, removing this conflict by specifying that BME recruitment should target students from ethnic groups that are under-represented at institutional level and from disadvantaged backgrounds.


Applying the Scots approach to institutional targets?

There is no basis for comparison between Scots and English system level targets because the measures and baselines are different.

But the obvious advantage of the Scottish approach is that it applies a universal minimum target to all institutions regardless of their starting point.

COWA’s Technical Paper reveals that its institutional target – 10% recruitment from students from the 20% most deprived backgrounds – will require the University of St Andrews to increase its recruitment from this quintile by 100% compared with a 2014/15 baseline, while the University of Edinburgh must improve by 67%.

Over a six year period numbers from such backgrounds would have to increase from 35 to 70 at St Andrews and from 120 to 200 at Edinburgh. The Commission says it believes these expectations are realistic and the (former) Scottish government agrees, as does the party most likely to form the next Scottish government.

This would be the obvious way to bind in highly selective institutions to the English target for improving participation from POLAR quintile 1.

So I tried modelling the impact on English Russell Group universities of a minimum target of 13.6% recruitment from POLAR3 Quintile 1 by 2020 – exactly half the value of the 27.2% national target.

Using 2014/15 outcomes as a baseline, my calculations suggest that some English Russell Group institutions would need to increase their POLAR3 Quintile 1 intakes by huge margins.

Oxford and Cambridge would each need to improve their intakes by over 300%. Even the best-placed institution – the University of Liverpool – would need an improvement of 32%.

On these assumptions there are more than 4,800 additional disadvantaged students to recruit into English Russell Group universities over a seven year period. These 20 institutions would be contributing some 62% of the additional recruitment required nationally.


COWA Capture


Institution 2014/15




Number missing Total (13.6% recruitment) Percentage increase needed
Birmingham 6.2 315 372 687 118
Bristol 3.8 150 383 533 255
Cambridge 3.3 85 263 348 309
Durham 4.4 140 290 430 207
Exeter 4.8 195 353 548 181
Imperial 3.9 45 111 156 246
King’s 5.3 140 217 357 155
Leeds 8.2 440 286 726 65
Liverpool 10.2 380 122 502 32
LSE 3.8 30 77 107 255
Manchester 8.6 480 274 754 57
Newcastle 8.7 340 187 527 55
Nottingham 6.6 320 336 656 105
Oxford 3.1 80 268 348 335
Queen Mary’s 4.2 105 232 337 221
Sheffield 8.7 355 195 550 55
Southampton 7.2 250 220 470 88
UCL 4 105 250 355 238
Warwick 5.4 140 210 350 150
York 7.7 225 169 394 75
Russell Group (Eng) 4320 4815 9135 111

Would it be feasible for Oxford and Cambridge in particular to triple their recruitment from POLAR3 Quintile 1 without relaxing A level attainment requirements?

Almost certainly not.

Perhaps the same level of expectation that now applies to St Andrews should be extended to all English Russell Group institutions: as a minimum each should double their 2014/15 intake from Quintile 1 by 2020 (or even 2021 if you prefer).

That would still account for more than half of the total increase demanded by the national target.


Applying the Scots approach to access thresholds?

The concept of access thresholds has been proposed by COWA to address a Scottish scenario very different to that in England.

The Commission describes a system in which demand is increasing but the number of university places is fixed. Consequently competition has increased and universities have progressively raised entry requirements beyond the level required to complete their degrees. This has made it much harder for disadvantaged learners to secure admission.

In contrast, number controls have been removed in England, although this has not led to universal expansion.

A substantial proportion of the most selective institutions are not planning student number growth. This report from March 2015 suggests that 12 of the 20 English Russell Group institutions were not intending to expand. This from January 2016 suggests that a few of the 12 have since changed tack, but there remains a core of institutions that will not increase their intakes.

COWA explains that, while the modest lowering of entry tariffs to support contextualised admissions is welcome, more radical action is required in Scotland:

‘Our proposal is for the formal introduction of separate entry requirements for the most disadvantaged learners for degree programmes right across the university sector. Rather than the market rate, these new access thresholds should be based on the minimum academic standard judged necessary to successfully complete a specific degree programme.’

They cite two existing access initiatives – a physics and astronomy gateway programme at St Andrews and a top-up programme at Glasgow – that are said to lower standard tariffs by between five and seven grades.

In fact, the entry requirement for the former is BBBB in Highers, including physics and maths, compared with a standard tariff of AAAA including physics and maths. (The standard A level offer is AAA including physics and maths.)

COWA propose an entitlement to entry for learners with care experience who meet the access threshold for the course for which they apply. This will come into operation in 2017, two years before such thresholds are proposed to become universal.

Pending the introduction of access thresholds, learners ‘should be assessed at the minimum entry levels’. This phrase is not clarified.

Since this recommendation has been accepted by the Scottish government, the clear implication is that access thresholds must also be introduced, even though the separate recommendation relating to their introduction is officially still under consideration.

But for other disadvantaged students achievement of an access threshold would not give an entitlement to entry. If thresholds do not contribute to improved rates of access, ministers are invited to consider options for developing them into an entitlement.

It is not at all clear why the arguments against entitlement for disadvantaged candidates – ‘there may sometimes be good reasons, unrelated to grades, why an applicant may not be a good fit for a particular course’ – do not apply equally to those with care experience.

COWA recommends that thresholds should be set ‘at a level which accurately reflects the minimum academic standard and subject knowledge necessary to successfully complete a degree programme’, but there is no guidance as to the process by which this should be established. Institutions would be responsible but the SFC would monitor carefully ‘to guard against any unintended consequences’.

Reactions are bound to be polarised with, on one side, those convinced that this is unfair to less disadvantaged candidates and, on the other, those equally convinced that such action is necessary to level the playing field for disadvantaged candidates.

Is there a case for imposing access thresholds on those English universities that have made least progress under the much more permissive access agreement regime?

If so, is there a robust methodology already in place to generate such thresholds, or is new work required to establish that methodology?



There is much to commend in COWA’s final report. There are a few logical inconsistencies associated with a failure to think through the sequence of implementation and the relationship between recommendations, but the broad direction of travel is welcome.

There is proper emphasis on securing cross-sectoral coherence, on eliminating wasteful duplication and on binding universities into the attainment-raising process led by schools and colleges. All have been consistent themes on these pages for as long as I can remember.

Of course it is so much easier to secure those outcomes in a country the size of Scotland – so much harder to take them to scale in England.

I live in hope that the system I have proposed for market regulation will one day be given serious consideration. But, though the government gives the impression that radical thinking is welcomed, there is little sign that it is really prepared to grasp the nettle.

Nor will the UUK-led social mobility advisory group be capable of pushing it in that direction.

But, if we are forced back upon some means to drive incremental progress in an irremediably fragmented system, the government could do worse than borrow, for inclusion in the HE white paper:

  • the notion of institutional access targets for highly selective universities, especially the English Russell Group and, as a last resort
  • the imposition of access thresholds –possibly even carrying entitlement to admission – on those institutions that consistently fail to make sufficient progress towards their access targets.

As I’ve intimated before, the present access agreement regime will not bear the weight of government ambition. Some degree of institutional autonomy must be sacrificed before any substantive progress can be achieved.



April 2016



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