Q: 1. Council of Directors of Institutes of Technology, Dublin 2

A:

Name: Dermot J Douglas

Title (Mr/Ms/Mr/Dr/ etc): Dr

Position (if applicable): Senior Academic Executive

Organisation (if applicable): Council of Directors of Institutes of Technology

Address: 4 Lower Hatch St., Dublin 2

County: Dublin

Telephone: 01 6769898

Fax: 01 6769033

Email: Dermot.Douglas@councilofdirectors.ie

WWW: councilofdirectors.ie

Date: 13-06-2003

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Organisational

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Submission: Fees Review - Review of Fees to be Charged by the Further Education and Training Awards Council and the Higher Education and Training Awards Council.

Introduction

The Council of Directors of Institutes of Technology welcomes the opportunity to contribute to the review of fees to be charged by the Awards Councils. The previous fee arrangements agreed between the Institutes of Technology and the National Council for Educational Awards (NCEA) were based on the statutory relationship between the Institutes and the NCEA (under section 5 (1) (b) the RTCs Act 1992 and the NCEA Act, 1979, Sections 1 (e); 3 (1) (2) (6); 9 (3) (4)). The authority to charge fees was covered by Sections 9(5) (6), 12 (1) and (18) of the NCEA Act and is covered by Section 17 of the RTCs Act. The RTCs Act modified, somewhat, the relationship between the RTCs and the NCEA. This led to a review of fees, which concluded in 1998 with a considerable reduction in the fees payable by Institutes to NCEA. This fee structure remained in place until 2001.
The Qualifications (Education and Training) Act, 1999 significantly changed the relationship between the Institutes of Technology and HETAC, which is the successor body to the NCEA. As a result of this, a new fees structure was negotiated which recognised the changing relationship between the Institutes of Technology and HETAC,
with Recognised Institutes undertaking additional functions previously provided by NCEA. The granting of delegated authority to make awards to four institutes and the stated policy of HETAC that delegation of awarding authority, to the maximum level to all Recognised Institutions of the Council (i.e. the IOTs), should be a policy aim of the Council, within the life of the current Council, has resulted in the need for a comprehensive review of the basis on which fees could and should be charged.

In coming to a determination on the fees to be charged, the Council of Directors believes that common principles should be applied to each of the Awarding Councils

Question 1 - Functions of Awards Councils

Do you agree with the description of the functions of the awards Councils described in this chapter? Are there other functions which the Authority should consider? Do you agree with the analysis of these functions as set out in this Chapter? How should this analysis be developed further?

The Council of Directors accepts that the description of functions of the Awards Councils is a fair and complete listing. However, the actual functions that an Awards Council will vary depending on the nature of the relationship between the Council and the client e.g. an individual learner seeking an award (validation of a programme would not be necessary); an industrial/business client (validation of company training, assessment procedures, making of awards), Private commercial providers, Recognised Institutes without delegated authority, Recognised Institutes with Delegated Authority. In relation to the functions listed on page 19 of the discussion document it is arguable that many of the functions listed are sub-sets of the singular function of reviewing the effectiveness of quality assurance procedures - namely ensuring fairness and consistency of assessment processes, review of delegation of authority, compliance with standards set by the Council for awards.
In coming to a view regarding fees to be charged, the Authority must take note of the additional functions imposed on the Recognised Institutes as a result of the new legislative arrangements and of the compelling need for the institutes to fund these new responsibilities. The Council of Directors recognises that, while we are in a transitional period, the basis for determination of fees should be rooted in the most likely future relationship between the Institutes and HETAC, which will see all institutes having been granted delegated awarding powers. Obviously, some transitional arrangements will have to be agreed to bridge the difference between the current stage of development of some Institutes and the desired future state for all Institutes. In making this determination, however, it is important to underscore the fact that the Recognised Institutes are funded through the public purse and that it would be invidious to expect the Institutes to sub vent the salaries and running costs of HETAC. Any fees calculation should be based on the additional costs over and above normal operational costs.
In terms of cost recovery from commercial clients HETAC must charge a reasonable but economic fee to avoid the charge of subsidising the private sector.

Question 2 - Issues Arising

Do you agree with the range of issues identified in this chapter? Are there other issues which the Authority should consider? Do you agree with the discussion on the issues set out in this Chapter? How should this discussion be developed further?

Unlike the situation with other providers, the Qualifications (Education and Training) Act compels the Recognised Institutions to seek validation, as appropriate, for all the programmes they organise, procure or provide from either HETAC or FETAC. This includes those situations where Institutes may have entered into arrangements with established Irish or European universities, professional bodies, foreign awarding bodies or vendor awards. This restriction does not apply to any other higher education institutions in the state. In the context of lifelong learning and part-time education, the requirement to pay additional fees in order to discharge a legal obligation could make such provision uneconomic. It is important to bear in mind that this provision applies equally to Institutes, which have been granted delegated awarding powers.

Institutes of Technology have responded to identified skills needs in the past through the development of so-called "consortium" courses. These courses have been designed by selected experts from a range of institutes and then offered throughout the sector. The practice has grown up in the past of charging a separate validation fee to each institute intending to offer the course, although the effort required on the part of the validation authority is no different than that required for a single course submission from an individual institute. The validity of this practice is questionable and is not encouraging of a flexible response to identified skills needs.

Question 3 - Consideration of Way Forward

Do you agree with the possible principles set out, in relation to the approach should be taken by the Authority in recommending a balance for the funding of the Councils between fees on the one hand and grant on the other? Should these be further developed or are there other principles which the Authority should consider? What is your view on the options set out? Do you agree with the analysis of the options? What steps do you think that the Authority should take now?

The ability of Institutes of Technology to pay fees to the Awards Councils is predicated on their ability to obtain sufficient income. Two sources of income are currently available a) the recurrent grant each institute receives from the Department of Education and Science and b) income received in respect of registration charges. Fees paid to awarding bodies, in respect of services provided, comprise an element of this registration charge. In the past this charge has been used to cover costs associated with examination and award fees charged by NCEA and HETAC.
Were FETAC to start charging fees on a similar basis to HETAC, then new or increased registration charges would be necessary to discharge this fee as well as providing appropriate Student Services.

In approaching the issue of fees the Authority should consider that the functions likely to be discharged by HETAC in relation to Recognised Institutions would, in the future, centre on quality assurance. The sub-sets of this overall function will determine 1) how well each institute is addressing its obligations in relation to maintenance of standards of its awards, programmes and the operation and management of the institute in relation to those programmes 2) the procedures it uses for quality assurance and how it evaluates those procedures 3) whether the institute is compliant with policies set by the Authority in respect of access, transfer and progression and 4) whether assessment procedures are fair and consistent for the purpose of achievement of an award by a learner. The totality of performance by an institute will determine whether or not delegated awarding powers are retained. It would seem logical, therefore, that a single fee might be set in respect of this overall function.

In the case of Institutes which have not yet sought or received delegated awarding powers, or who are offering further education awards the totality of services provided by HETAC or FETAC will be different, Fees should be charged, in this case, by the relevant Council on the basis of the additional cost of the service they provide (as per Option 3). Given that the Councils may provide services in respect of any learner, the scale of fee charged for each service should recognise that the Councils and the Recognised Institutes are both funded by the State and that additional charges will represent a levy on the learner and should not, therefore, be excessive.