A Blueprint for Fairness: Final Report of the Commission on Widening Access

Chapter 4: The Architecture to Support Fair Access

It is important that the recommendations for change we have made thus far are complemented with the right architecture to support delivery. We must ensure that we are making the best use of available funds, targeted at the most effective activity to support fair access. We also need to utilise our data to its full potential and develop improved data systems so that information supports and enhances what we do rather than acting as a barrier to progress. Robust regulation will be necessary to monitor and drive progress and this must sit alongside a set of targets that make clear our ambition and expectation for change.

Funding

Within this report we have highlighted the need for tailored and targeted support (including pastoral care) for learners to support access and retention along with additional activity such as the expansion of bridging programmes and articulation. All this requires funding. Consideration has to be given to whether these costs can be met through reallocation of existing resources or whether additional funding will be required. There is also a question of what institutions might be expected to deliver within the bounds of current funding and what might require additional resource. While we are very clear that access should already form part of the sector's core mission - and we are encouraged by the commitment that institutions have made to access to date - it is nevertheless reasonable to explore whether current funding is being used to best effect and whether there are more creative ways of providing funding to the sector that delivers change and eases any additional or transitional financial pressures associated with fair access.

Recommendation 24: The SFC should review the best use of its funds, specifically the Access and Retention Fund, to deliver the implementation of the Commission's recommendations.

Recommendation 25: The SFC should monitor how institution spend from core funding is being used to support access through the Outcome Agreement process.

Firstly, we need to better understand how much is currently being spent on supporting access across institutions, the effectiveness of that spend and what funding might be required going forward. We also need to consider how to make best use of the funding for access provided directly by SFC. We are aware that the SFC has recently reviewed the Access and Retention Fund, but we believe it should be reconsidered again in light of this report.

The Commission also discussed options to drive progress through better targeting of core funding towards access students or access activities, such as differential teaching grant for access students or ring-fencing a portion of funding for access activity. Further work is needed to assess the feasibility of alternative approaches to target funding and their likely impact. Options for more targeted funding models should be considered in the second phase of implementation; by which time we will have a greater understanding of the impact of the recommendations delivered in the first phase.

Recommendation 26: By 2021, the SFC, in consultation with the Scottish Government, should explore options for more targeted funding models to better support the recruitment and retention of greater numbers of access students.

While the Commission is clear that it is not within our remit to consider how higher education is funded in Scotland, the Commission has discussed how we deliver fair access to university within a system with a fixed number of funded places for undergraduate students. We are mindful that the introduction of access thresholds may raise concerns about the displacement of other applicants. It is our belief, however, that if we are serious about achieving a fairer Scotland, this will require some movement across the system and a breaking down of entrenched patterns of advantage. We are also aware of the breadth of opportunity being developed for young people in Scotland. The Developing the Young Workforce programme is delivering new vocational pathways and higher level apprenticeships. We do not take the view that higher education in university is the best or only option in Scotland; nevertheless it has to be an option that is available to people from all parts of our society.

There are a number of options (which are not mutually exclusive) for increasing the number of higher education students from disadvantaged backgrounds:

• the system could be grown to increase the number of places to support the entry of a greater number of students from disadvantaged backgrounds;
• the current number of places available could be used more equitably, e.g. through use of minimum entry thresholds; or
• provision could be restructured to make best use of the places that are available, for example, by removing unnecessary duplication of study years where this is not a requirement for a student to succeed.

The Commission has focused on how we make access fairer within the current system. It is for the Scottish Government to determine the size the higher education sector required to deliver the skills necessary for economic growth. If the Government chooses to make changes to the current system then it should, of course, consider how such changes might be used to best effect to support fair access.

Regulation

We recognise that harnessing the commitment, capacity and capability of the education system and those who work in it is critical to achieving progress on access. But it needs to be underpinned by a framework of regulation. In our interim report, we indicated our intention to consider whether Scotland has in place the necessary regulatory arrangements to drive progress and to ensure appropriate levels of accountability.

We have examined the merits of various regulatory models, including the possibility of an independent access regulator. However, on balance, we are agreed that the most appropriate solution is to build upon the existing regulatory framework, and the established relationships which underpin it, rather than introducing an additional layer of complexity and bureaucracy which risks duplicating arrangements already in place. The Commissioner for Fair Access will play a key role in harnessing the best use of existing regulation, across all sectors, to support fair access.

Post-16 Regulation

In terms of post-16 education bodies, the SFC already possesses substantial regulatory powers in relation to fair access, including relatively recent powers under the Post-16 Education (Scotland) Act 2013, which give it the authority to require outcome agreements, set targets and to attach stringent conditions to the award of public funding.

In line with the increased emphasis being placed on fair access by Ministers, we believe that going forward the SFC should consider more extensive use of these powers where that is deemed necessary to drive progress, both in relation to overarching targets and on more specific access issues such as articulation and access thresholds.

We also recognise that the extent to which regulatory powers are exercised is dependent on the strength of the mandate passed to the SFC by the Scottish Government. Ministers should therefore ensure that their guidance to the SFC provides the necessary level of authority.

Wider Regulation

We repeat again that ensuring fair access is an objective that can be achieved only if every part of the system maximises its contribution. Therefore we believe that there is a strong argument for embedding fair access into the regulatory frameworks of all sectors with a responsibility to support it, e.g. for schools and providers of early learning who have a role to play in closing the attainment gap and raising aspirations and expectations for learners from disadvantaged backgrounds to study higher education. In implementing this, the cross system voice of the Commissioner for Fair Access could be crucial.

Recommendation 27: The SFC should make more extensive use of their existing regulatory powers, where appropriate, to drive greater progress. The Scottish Government should ensure that it provides the SFC with the necessary mandate to take this action.

Recommendation 28: The Scottish Government should ensure that objectives relating to fair access are embedded in the regulatory frameworks of other agencies/public bodies with a role to play in advancing equal access.

Better Use of Data to Support Fair Access

In our interim report we discussed how Scotland is not making best use of the data it has to support fair access i.e. through the sharing and linking of data across sectors to provide insightful analyses. More could be done with the data that we have to support and understand the progress that Scotland is making to achieve fair access. Enhanced monitoring at key stages of the education journey, better comparative information and a more coherent approach to publishing data will help to develop the evidence base.

But it is not enough to simply present 'snapshots' of progress in different areas; we need to join our data systems together. A more systematic approach to the use of data is required and fundamental to that is the ability to track learners throughout their education journey. A unique learner number, used appropriately by all parts of the system, would help sectors to share information to support learners as they transition from one stage of learning to another. It would also facilitate better data linkage and tracking of individuals to improve our understanding of outcomes, which in turn will inform our assessment of the impact of activity. A unique number could be based on existing identifiers within the system e.g. the Scottish Candidate Number, or could be delivered through a new approach.

Building a coherent data system will take time but now is the time to start. Enhanced use of data to support work with those from disadvantaged backgrounds is already being explored within education policy e.g. the Early Years Collaborative and the National Improvement Framework are looking at enhanced monitoring. Scotland needs a data system that focuses on the learner and their progress, rather than the institution or establishment they attend.

In our interim report we noted the lack of UK comparator measures that could be used to robustly assess relative progress on access across the UK nations. Scotland must be able to compare its progress against that of others if it is to identify areas for improvement and the best solutions for fair access. A consistent and valid UK comparison would be a first step in making this possible.

We are mindful of the timescale of our remit. By 2030 the data and technology available to us will have changed. We are therefore keen to explore how new data science solutions can be developed to support fair access activity going forward. For example, the ability to use detailed data on individuals to identify those who would benefit from interventions and the interventions that would be most effective for them. This is something that The Data Lab, Scotland's new Data Science Innovation Centre, could assist with.

Recommendation 29: The Scottish Government should improve mechanisms to track learners and share data to support fair access. Specifically, the Government should

• lead the work necessary to develop and implement the use of a unique learner number to be used to track learners' progress from early learning, throughout education and onwards into employment.
• review data access arrangements to provide a national process for the provision of information to practitioners and policy makers working on fair access. This review should consider access to and sharing of data held by local authorities, schools, UCAS and SAAS.

Recommendation 30: The Scottish Funding Council and the Scottish Government should enhance the analyses and publication of data on fair access. This should include:

• enhanced monitoring of fair access at key stages of the learner journey including analyses by socioeconomic background of: early learning and school attainment; UCAS applications, offers and acceptances; entrants to higher education; qualifiers from higher education and their destinations.
• publication of a coherent and consistent set of statistics to show progress on fair access, either through development of the SFC's Learning for All publication or a successor publication.
• working with UK producers of statistics, including HESA and UCAS, to develop an agreed method of comparing progress on fair access over time and across UK nations.
• exploring with The Data Lab the feasibility of a project to develop a data science solution to support fair access e.g. a schools based data solution to identify those from a disadvantaged background with the potential to succeed in higher education and who could most benefit from additional support.

Measures to Identify Access Learners

As we discussed in our interim report, the use of data to support access is one of the areas that has been brought to the attention of the Commission repeatedly. Much of this discussion has focused on how we define deprivation and, in particular, the limitations of the current approach, which focuses on use of the Scottish Index of Multiple Deprivation ( SIMD). This was an area that the Commission was committed to exploring in its work, not least, because it was felt that the debate about how we measure deprivation was, at times, overtaking the discussion on how we might achieve fair access.

The main concern expressed on the use of SIMD is that it is an area based measure and therefore is less likely to capture individual circumstances. Also, because SIMD identifies geographical concentrations of deprivation, it is less likely to identify those from disadvantaged backgrounds in more rural areas where the population is more geographically dispersed. This has led some universities to question the use of SIMD alone for access related targets and funding, as they consider that it does not capture the individuals they are currently supporting and those from disadvantaged backgrounds in their local population.

In our interim report we recognised that different measures are required for different purposes, including real time data to support decisions about individuals and data to support targets to monitor progress - and that the solution for these purposes may be different. The Commission brought together an expert group to explore the issues around data and evidence, including what measures could be used in addition to SIMD to identify those from disadvantaged backgrounds. There was a clear consensus that a set of measures, which includes SIMD but also a measure of an individual's income circumstances and their school environment was important for use when making decisions about individuals.

The Commission looked at the data currently available in the education system that could be used to help identify individuals from disadvantaged backgrounds. In its assessment, the Commission considered:

• What variables could be used as a marker of low income or school environment
• The robustness and coverage of these variables, along with their validity in terms of identifying disadvantage and their overlap with SIMD20
• Whether or not the use of these variables could be implemented across all parts of the education system
• The distribution of learners identified by these markers across Scotland
• The viability of their use for institutional and national targets
• Other data development work underway, or being considered, in the education sector that was relevant to this area.

The Commission has published, along with this report, a separate paper setting out the results of this analysis. The main findings are:

• Uptake of Free School Meals ( FSM) was considered as a proxy measure for low income; however there are issues with coverage of this measure.
• Attendance at a secondary school with low progression to HE was considered as an indicator of school environment; however there are issues with the robustness of this measure.
• There is a strong correlation between SIMD and the other two measures i.e. those from more deprived areas are more likely to register for FSM or attend a low progression school; however around half of those receiving FSM and in a low progression school do not live in SIMD20 areas.
• The only measure of deprivation that is available, and used, across the entire education system is SIMD.
• None of the measures considered, either singly or in combination, identify a group that is more evenly distributed across Scotland i.e. regardless of the measure used, the spread of deprivation varies across Scotland.
• There are a number of areas of policy development in Scotland e.g. Early Years Collaborative, expansion of early learning and childcare, the National Improvement Framework and work to close the attainment gap; all of which are designed to support those from disadvantaged backgrounds and are looking at enhanced use of data to support this.

There is no doubt that the more sophisticated and targeted we can be when providing support or making decisions about individuals the better. However, we also need an approach that is based on valid measures and allows us to monitor progress by institutions, and as a nation, to deliver fair access.

It is our view that a more individualised approach to identify those from disadvantaged backgrounds would be beneficial but that this would need to be adopted across all parts of the education system if we are to provide coherent support for individuals to drive forward fair access. A more individualised measure would also need to be relatable to the wider population if it were to be used for targets and monitoring. At this stage, it is the Commission's view that we do not have robust and valid data to implement this approach across all access work in Scotland. The Commission would, however, be supportive of any moves to develop a more individualised approach to measuring deprivation for use across the entire education system should the data become available to do this.

Despite the limitations outlined earlier, the Commission believes that SIMD is a valid marker of deprivation. SIMD is based on a wide range of data, covering a number of domains relevant to deprivation; unlike the additional measures we have explored, which focus on a single aspect. SIMD is also used as a marker for deprivation across the Scottish public sector, including all parts of education. It is therefore the Commission's view that SIMD should continue to be used for tracking, monitoring and targets relating to fair access in the coming years. The use of SIMD for these purposes must, however, recognise the distribution of those living in SIMD20 areas across Scotland and this should be reflected both in the expectations of, and reporting on, progress for individual institutions.

We also recognise that additional measures, like those identified above, can help with decisions about individuals and the support they require - a process that is already happening in some institutions for example, to inform contextual admissions. A consensus, however, needs to reached on the best and most reliable measures to identify individuals for these purposes so that we can be more consistent in the support and opportunities provided to learners across Scotland.

Recommendation 31: 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.

• In addition to SIMD, this should include a measure for school environment, a marker for income and a marker for care experience.
• The development of these measures should take account of the findings from SFC funded research on the use of contextual data in undergraduate university admissions being undertaken by Durham University and due to report in 2016
• The SFC should review the measures it uses within outcome agreements and the access work it funds in light of the outcome of this work.

Targets to Realise Our Ambition

The Commission was asked to propose both a short and long-term target for increased participation in higher education. We are aware that progress to improve attainment will be monitored through the Early Years Collaborative and the National Improvement Framework; in this section we set out our expectation for the part that post-16 institutions can play in delivering fair access.

In developing these targets we have considered the need to ensure that increased participation in one part of the post-16 sector will not be at the expense of participation in another part; we have therefore included a recommendation for equality of access in both colleges and universities. We are aware, however, that it is progress within universities that is necessary to deliver equal access and therefore we have provided interim targets for this sector to drive progress in the coming years.

In our interim report we noted the significant variation across institutions in the level of participation for those from deprived backgrounds. It is our view that every individual college and university in Scotland should be expected to work towards equality of access to higher education for its entrants. The Commissioner for Fair Access should ensure that the SFC works with institutions to identify how further and faster progress can be made to this end through development of stretching targets within the Outcome Agreement process. Consideration should be given to the deprivation levels within the local population when discussing expectations for progress with individual institutions; however consideration should also be given to how institutions can better support access students to attend institutions from outwith their local area if they wish to do so. While recognising this variation between institutions, the Commission also felt it was important to make clear our expectation of each institution's contribution to fairness, by setting a level of participation below which we feel is unacceptable. We have therefore included a target to ensure that no institution in Scotland has fewer than 10% of its entrants from the 20% most deprived backgrounds.

We believe that the targets below are both necessary and achievable.

Recommendation 32: The Scottish Government and the Scottish Funding Council should implement the following targets to drive forward the delivery of equal access in Scotland:

To realise the First Minister's ambition of equality of access to higher education in Scotland:

• By 2030, students from the 20% most deprived backgrounds should represent 20% of entrants to higher education. Equality of access should be seen in both the college sector and the university sector.

To drive progress toward this goal:

• By 2021, students from the 20% most deprived backgrounds should represent at least 16% of full-time first degree entrants to Scottish universities as a whole.
• By 2021, students from the 20% most deprived backgrounds should represent at least 10% of full-time first degree entrants to every individual Scottish university.
• By 2026, students from the 20% most deprived backgrounds should represent at least 18% of full-time first degree entrants to Scottish universities as a whole.
• In 2022, the target of 10% for individual Scottish universities should be reviewed and a higher level target should be considered for the subsequent years.

For the purpose of these targets, students from the most deprived backgrounds are defined as those from SIMD20 areas. We recognise, however, the particular challenge that the use of SIMD as a marker for deprivation presents to institutions in the north east of Scotland. SFC should therefore consider additional measure(s) to SIMD when monitoring the progress of Robert Gordon University and the University of Aberdeen towards the above targets, which better reflects the link between deprivation and access in the local population.