Q: 2. Higher Education and Training Awards Council, Dublin 1

A: Response of the Higher Education and Training Awards Council (HETAC) to the National Qualifications Authority of Ireland (NQAI) Consultation Document on the Review of Fees to be charged by FETAC and HETAC.

1. The Higher Education and Training Awards Council (HETAC) welcomes the consultation document and notes that the determination of fees is a matter ultimately for the Minister for Education and Science in consultation with the Council.

2. It wishes to point out that the reference to the arrangements for 2003 referred to at the end of page 10 should include the following addition after 2003:- "excluding the flat fee of €40,000 for each of the four institutes of technology with delegated authority". The following should be substituted for the last line on page 12:- "Total Fee income for 2002 was €1,658,998" (the €1,089,728 quoted excludes the evaluation fee income of €569,270). It should be noted also that "recognition fees" (referred to in pages 9 and 10) have not been charged by HETAC since its establishment.

3. From the academic year 2004/05 it is planned that all providers will follow the arrangements for the Institutes of Technology in appointing their own external examiners and pay for the costs associated with them. This will lead to a further reduction in HETAC income from award fees. As more institutes of technology are granted delegated authority to make awards over the next few years, HETAC income from award fees and evaluation fees (its present main source of fee income) is set to fall substantially. The present level of award fees and evaluation fees has fallen in real terms over the last few years. Fees for validating new programmes (evaluation fees) have remained at their current level (€6,920) since 2001.

4. Fees could also be charged for the other functions referred to on page 23, namely agreeing and reviewing quality assurance procedures, ensuring fairness and consistency of assessment processes, processing applications relating to requests for delegation of authority and subsequent reviews etc. The level of such fees should, however, not hinder innovation and the increasing certification of learning. Account has also to be taken of the administrative costs associated with the collection of a wide range of fees and HETAC is strongly of the view that fees payable to it by providers should be simple and easily understood by all stakeholders.

5. As constituted, HETAC is a Public Body with a significant role in higher education and training relating to the setting of standards, validating programmes, making awards, delegating awarding powers, ensuring that student assessment procedures are fair and consistent, monitoring quality assurance and review. Accordingly, it must not be over reliant on fee income from its provider institutions. Section 11 of the Act provides that in each year the Minister shall pay to the NQAI a grant and that the Authority from that funding may pay a grant to the Council (subject to such conditions as the Authority shall decide). In arriving at a figure for such a grant the Authority reviews, discusses and approves the overall budget of the Council. Section 61 of the Act provides that the Council may charge fees in relation to the performance of its functions. The level of fees are determined by the Minister.

6. Thus the Authority agrees a budget with the Council and makes a grant to cover that part of the Council's expenditure which is not covered by fees set by the Minister. While the Council may have a view relating to the appropriate balance between fees and grant and has a right to be consulted in advance of the Authority's and Minister's determinations, it has no right to decide what the balance should be. It does, however, have the right to be funded to such extent as enables it to meet its statutory obligations and fulfil its statutory functions. Ideally it should be funded from the recurrent grant paid by the NQAI to the extent of at least 75% of its annual financial requirements with the balance (25%) coming from fee income. However, any shortfall in projected fee income in meeting that contribution should be made good by an appropriate increase in the grant from the NQAI. Subsidisation of publicly funded bodies by private sector organisations is not an appropriate basis of public policy and may not accord with European Directives. The Council believes that the bodies established under the Qualifications (Education and Training) Act, 1999, should be treated equitably.