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The ISM tells government why its Higher Education proposals will damage arts courses

The government is currently consulting on plans to reform Higher Education (HE) courses, including introducing caps on student numbers and restricting access to loans. The ISM believes these proposals will cause particular harm to arts courses, as well as damaging the government's own levelling-up agenda.

We have made these points in our response this week to the Department for Education's (DfE) consultation, and we urge ISM members to submit their own responses to the consultation to tell the government why these proposals are potentially so damaging to our sector.

The consultation is part of the DfE's Review of Post-18 Education and Funding and an independent panel, chaired by Sir Philip Augar, produced a report for the review in May 2019. The consultation builds upon the HE elements of that report.

The independent panel's report found that 98% of full-time degrees are now charged at the maximum rate and the consultation states that, 'an "over-funding" of lower-cost subjects relative to higher cost subjects has created perverse incentives for providers to prioritise lower-cost courses over higher-cost courses. Yet, higher-cost courses, such as STEM provision [science, technology, engineering and maths], are often better investments for students, society and the economy.'

This ignores the fact that the music industry alone contributed nearly £6bn per year to the UK economy in 2019, while overall the creative industries contributed nearly £116bn (5.9% of the UK economy). HE arts courses are a vital part of the talent pipeline that supports our creative industries, and they are as valuable as STEM courses.

The reforms also propose assessing courses by how many graduates progress to 'professional or managerial' roles, which does not take into account the fact that performing arts graduates can take time to establish their careers and often do not follow typical career pathways.

The DfE is further proposing to set Student Number Controls (SNCs) and Minimum Eligibility Requirements (MERs) for HE courses. The ISM believes both of these initiatives will harm the government’s levelling-up agenda by disproportionately affecting students from poor and disadvantaged backgrounds.

The consultation closes on 6 May 2022.

    ISM response to the consultation

    We encourage ISM members to submit their own responses to the online consultation. You can use the ideas below, adding your own experiences where appropriate:

    6. What are your views of SNCs as an intervention to prioritise provision with the best outcomes and to restrict the supply of provision which offers poorer outcomes? If you consider there are alternative interventions which could achieve the same objective more effectively or efficiently, please detail these.

    The ISM does not agree with the use of SNCs for the following reasons:

    The government’s proposals for SNCs are potentially highly damaging for music and other arts courses. The consultation states that ‘higher-cost courses, such as STEM provision, are often better investments for students, society and the economy.’ However, the music industry alone contributed nearly £6bn per year to the UK economy in 2019, and overall the creative industries contributed nearly £116bn (5.9% of the UK economy). Arts courses are a vital part of the talent pipeline that supports our creative industries, and they are as valuable as STEM courses.

    The proposals for SNCs include reducing numbers on courses with higher drop-out rates. This fails to take into account that some HE providers have large numbers of students from disadvantaged backgrounds. These students are more likely to drop out of courses due to economic or social reasons rather than academic ones, and therefore drop-out rates do not necessarily reflect the quality of the courses. It is far better to monitor the quality of courses in other ways.

    If a HE course is sub-standard, the solution should be to support improvements, not to restrict the numbers of students, in the same way that a failing school is supported.

    SNCs should not be implemented at any of these levels for the reasons given in our previous answer: the proposal shows a misunderstanding of why students drop out of courses; the system should support improvements in HE courses rather than restricting opportunities for students to access courses.

    8. The Government is considering which outcomes should be used if SNCs are introduced and has identified the three broad categories as quantifiable, societal, and/or strategically important. What are your views of the merits of these various approaches to consider outcomes and/or do you have any other suggestions?


    The ISM is concerned about the proposal to review course outcomes for the purposes of setting SNCs under the categories of ‘quantifiable, societal, and/or strategically important’:

    The focus on ‘progress to managerial and professional employment’ is concerning: it is unclear how these terms will be defined, but we believe this approach is likely to be detrimental to courses in the performing arts, where students can take time to establish careers after completing their education.

    Performing arts graduates may well be self-employed with a portfolio career split between, for example, performance and teaching, or they may support a performance career with work in another area altogether.


    9. Do you have any observations on the delivery and implementation of SNCs, including issues that would need to be addressed or unintended consequences of the policy set out in this section?


    Using drop-out rates to assess the viability of a course will disproportionately affect HE institutions with larger cohorts of poor students, as pointed out in previous answers. The likely impact will be to disadvantage students from poorer backgrounds, counter to the government’s levelling-up agenda.


    10. Do you agree with the case for a minimum eligibility requirement to ensure that taxpayer-backed student finance is only available to students best equipped to enter HE?


    The ISM does not agree with the case for a minimum eligibility requirement.

    The introduction of a minimum grade requirement will disproportionately affect the poorest students, who are more likely to have lower grades because of the disadvantages they have faced in their schooling. HE is a key route to social mobility, so it is vital that students who can benefit from a university education are able to do so regardless of their background.

    HE providers are well qualified to assess a student’s ability to complete a course and it is both in their interest and their responsibility to ensure that students are accepted on to appropriate courses.


    11. Do you think that a grade 4 in English and maths GCSE (or equivalent), is the appropriate threshold to set for evidence of skills required for success in HE degree (level 6) study, managed through their eligibility for student finance?


    No. Any student accepted on to a course should be eligible for a student loan.

    The DfE’s own data shows that in 2019 (the last year that GCSE exams were taken before the pandemic) 35.6% of students from state schools in England did not achieve a grade 4 or above in both English and maths. That’s over a third of state school pupils who would then be excluded from student loans.

    This policy would also exclude students who underachieve at GCSE level for reasons other than academic ability and who are capable of flourishing at HE level. These students are often from disadvantaged backgrounds, so this policy would go against the government’s levelling-up agenda.


    12. Do you think that two E grades at A-level (or equivalent) is the appropriate threshold to set for eligibility to student finance, to evidence the skills required for success in HE degree (level 6) study?


    No. Any student accepted on to a course should be eligible for a student loan.

    This would exclude students who underachieve at A level for reasons other than academic ability and who are capable of flourishing at HE level. This policy would disproportionately affect students from disadvantaged backgrounds and go against the government’s levelling-up agenda.


    13-18. These questions cover various proposed exemptions from MERs


    The ISM disagrees with the policy of MERs overall.