Ten things everyone working in or studying art should know...

Andrew McGettigan

Contexts / 22.07.2011

With some chutzpah, given its proposed displacement of degree costs onto individual graduates, the UK government has titled its newly published ‘White Paper’ on higher education in England Students at the Heart of the System. Such a document is supposed to set out a clear vision for future changes to policy and legislation, but this one is a frustrating read; much of the detail one might expect is displaced into a series of reviews and consultations (I have counted at least fifteen) launching, reporting and concluding at various points over the next few months.

It is possible, however, to outline its broad contours. There are several proposals which will adversely affect the sector overall: the increased cost to individuals, the consequent worsening of accessibility to higher education and the enabling of new, for-profit colleges to compete ‘on a level-playing field’ by granting their students access to publicly-supported loans.1 Here, I will highlight and unpack what I believe to be the most important proposals for undergraduate degrees in Fine Art.

Controls on student numbers

Under current arrangements, each public higher education institution has a designated ‘recruitment cap’ which determines how many undergraduates it is able to admit annually. The White Paper proposes the managed ‘liberalisation’ of this central imposition on student numbers over the medium term, but initiates this process in two distinctive and more complicated ways from 2012/13. Owing to the government and media focus on Oxford and Cambridge, the impact on other kinds of university and college may be underestimated.

#1. The government creates a smaller ‘core’ recruitment cap and a ‘pool’ of applicants who can be freely recruited.

§4.19 We propose to allow unrestrained recruitment of high achieving students, scoring the equivalent of AAB or above at A-Level. Core allocations for all institutions will be adjusted to remove these students. … We estimate this will cover around 65,000 students in 2012/13. AAB will represent a starting point, but our ambition is to widen the threshold over this parliament, ensuring that the share of places liberated from number controls altogether rises year on year.2

The recruitment quotas at each institution, whose numbers will make up the ‘core’, will be reduced in line with the proportion of current students who attain/score AAB or above at A-level: the more students who hold these grades a university has, the fewer students will be counted in the core available to universities. So if UAL has twenty per cent of students with AAB+ now in 2011, then its core in 2012 will be lowered by that amount.3

Illustrated Example 1. University B is currently allowed to recruit 2,000 students per year. Twenty per cent of those students have achieved grades AAB or above at A-level

Beyond this core allocation, colleges and universities will gain additional, bonus places if they recruit from this pool of new applicants who score AAB or above. This will impact on art courses and, more pointedly art and design colleges, even though they do not by and large select students based on A-level results. For example, official HEFCE figures show that 11% of University of the Arts London students have AAB and above. UAL will lose this percentage from their core, even though they predominantly use different admissions criteria.

Illustrated example 1, continued. For 2012/13, University B will have a ‘core’ recruitment cap of 1,600 and loses 400 students to the 65,000-strong pool of AAB+ candidates. If it wishes to replace those numbers it has to aim for AAB+ achievers – thus it may recruit more students than it was able to previously by competing strongly for them, but it may also lose out

As this boundary between ‘core’ and ‘pool’ is lowered year on year to expand the latter at the expense of the former, more and more students will be lost from the core number that an institution may recruit. To make up these losses, an institution would either have to recruit more overseas, non-EU students (where there are no caps on recruitment) or alter its application procedures to recruit directly from the pool. In the case of arts institutions, a dual-track application procedure may be needed to ensure sufficient students holding AAB+ are recruited.

#2. A further reduction in the core creates a second pool of applicants for whom only ‘low-cost’ providers can tender.

§4.20 The second element is the creation of a flexible margin of about 20,000 places in 2012/13 to support expansion by providers who combine good quality with value for money and whose average charge (after waivers have been taken into account) is at or below £7,500. Places will be removed from institutions’ core allocation on a pro-rata basis, once AAB places have also been removed. This will create a margin of places, which will then be competed for on the basis of agreed criteria.

Every institution will see their core recruitment numbers further reduced by roughly 8% to create a second ‘pool’ outside institutional caps. This pool operates differently from the first one: that was a pool of applicants determined by individual examination results, while this one is a pool of places for which institutions can bid prior to applications from individuals so as to supplement their core recruitment allocation (now cut from two directions). Only one criterion for this bidding process has so far been specified: only institutions whose average fee charge per student is £7,500 or under will be eligible to bid (once fee waivers have been factored in).

Student places will be lost to this pool regardless of what courses are offered at this cheaper cost: that is, places lost from specialist art and design colleges may be taken up by new business and accountancy colleges. Institutions whose average fee is over £7,500 simply lose places as they are banned from bidding. Institutions that bring down their average fee to the necessary level will not necessarily keep their places – they will be allowed to go for replacements, and more, but with no guarantee of success. The Call for Bids goes out in October 2011 and closes in December.

Illustrated example 2: approximately eight per cent of places will be lost to a pool of seats reserved for courses costing less than £7,500 per annum

#3. The core shrinks each year. There is no ‘do nothing’ scenario.

This new, artificial mechanism for controlling student numbers is a zero sum game – overall, there are no new additional places. In 2012/13, a quarter of all student places (85,000) will lie outside the core, institutional caps. According to the expressed intentions of the White Paper, the ‘core’ will then shrink further each year as the pools are expanded and institutions will have to decide how to maintain current numbers, whether through additional overseas recruitment (which carries a political risk given new restrictions on student visas, which is already affecting recruitment) lowering fees, closing courses, shifting to more postgraduate or short course provision or changing recruitment practices. Further, more drastic options are discussed below.

#4. Bringing fees under £7,500 per year is difficult without reducing levels of resourcing.

There is no ‘London Weighting’ in the new proposals. Under the previous funding arrangements, for a ‘studio-based’ undergraduate place (so-called ‘Band C subjects’ like art and design courses) an institution received: annual tuition fees of around £3,300, plus a central grant of approximately £3,900. While this comes to about £7,200, institutions within ‘inner’ and ‘outer’ London would have received additional grant of approximately, £400 and £250, respectively, to cover higher overheads, in particular salary costs.

Further, the increase in tuition fees is not just meant to cover the loss of the central teaching grant. When seeking permission to set fees above £6,000 per year, institutions had to commit to spend a percentage of the additional money on initiatives aiming to improve participation from social classes and communities with little experience of higher education. Nationally, approximately 25% of this additional money is promised to the improvement of ‘access’, whether through outreach programmes, fee waivers or maintenance bursaries to students from poorer backgrounds.

That is to say, if an art course in London sets its fees at £7,500 per year, it is likely to be less resourced than previously, despite the individual student seeing the headline cost more than double. For this reason, many institutions set their fees at the maximum £9,000 for 2012/13 with the intention of maintaining and even improving the resources available to undergraduate study.

The universities' core of students, having excluded high-achieving candidates and lost a percentage to cheaper courses, is potentially reduced from two sides

#5. Art departments or courses in large arts and humanities universities may be better positioned if an institution introduces differential fee rates.

Across a large college or university, the average fee cost per student place is a very crude measure. Studio-based subjects within large universities also offering arts, humanities and social sciences (‘Band D’) subjects may benefit. This is because those other subjects previously received a lower level of central grant, which means it ought to be possible to charge lower fees for such courses.

If an institution sets a lower fee for a subject like history and a higher fee for a studio-based subject, the overall average student fee for the institution may be under £7,500 without any need for cross-subsidy. If an institution has several hundred humanities or social sciences places for which it can charge under £7,500, the effects of averaging can support a smaller number of studio-based courses charging a higher fee to meet additional costs, while enabling the institution to bid for the new pool of lost cost places.

It may be much more difficult for specialist art and design institutions offering a majority of studio-based courses to follow a similar strategy – it would need to expand numbers on whichever courses it could run more cheaply.

Direct funding and ‘priority’ subjects

#6. There is a consultation on direct grant funding to certain subjects and kinds of institution.

The White Paper aims to identify subjects, alongside science, technology, engineering and mathematics (STEM), that should continue to receive direct funding support through grants. The review of these ‘priority subjects’ will conclude in September. There have been calls for Design to be recognised in this way. If successful, some teaching grant would then enable fees in design degrees to be reduced.

Small and specialist institutions like art colleges also currently receive targeted allocations through the teaching grant. With the latter abolished, there will be a further consultation on whether to continue with such funding. The White Paper discusses ‘arts and music conservatoires’ (§1.10 & §1.26) in the context of such funding in recognition of the intensive teaching environments found there.

The money here will go to small institutions , such as the Royal Northern College of Music or the Central School of Speech and Drama, not necessarily to larger universities offering the same subjects. This might make performing arts more viable in the conservatoire setting and again forces institutions to consider what they should be offering in new ways. That said, this is wrapped up in a consultation so there may be scope to avoid such disparities.

Such direct funding, for those eligible, would enable courses to be run at a lower fee rate, because costs would now be supplemented by central money. However, were design or performing arts to receive such money, but art not, we can begin to see a new objective pressure, an imbalance in favour of design or performance, working against the current formation of specialist art and design colleges.

When considered alongside the emphasis in the White Paper on industry links and ‘training for employability’, which design will also be better placed to exploit, such pressures are augmented. For example, the promotion of ‘off-quota’ courses sponsored by employers (§3.33 ff.), now far more attractive to universities given the complex recruitment issues already discussed, will better exploited by design courses than art.

§3.36 Bespoke employer ‘closed courses’ are already exempt from current entrant controls. In Chapter 4 we explain how we will exclude from any number controls, those places where employers meet students’ tuition and other costs up-front, thus negating the need for students to draw on public funds. This will ensure there are no Government-imposed limits on the expansion of this employer-supported provision.

Under such policy conditions, Fine Art, owing to its funding status, would have more ‘affinity’ with humanities subjects than with those with which it has been traditionally associated.


There has been some recent discussion in the art world about whether art in general is best advanced by the university framework.4 While given the pressures on numbers described above, it is understandable that some university managers see the attractions of stepping outside of the government’s regulatory control. There are major implications for both these senses of ‘independence’ in the White Paper.

#7. The White Paper is a charter for independent ‘start-ups’.

The White Paper is in some sense a charter for independent ‘start-ups’ – new private enterprises offering university-level education – in that it promises to simplify access to degree awarding powers in particular by reducing the number of students needed to qualify (§§4.33 & 4.34) and by promising less onerous restrictions of teaching track records (§4.27). Since there is now no central teaching grant provided to undergraduate art degrees from the Exchequer, the key distinction between private and public universities is erased: any institution, regardless of whether it is a charity or a profit-making vehicle, will have access to the publicly supported loan scheme on the same terms, so long as it meets specific requirements.

The government’s notion of ‘Big Society’ means it is amenable to ‘John Lewis-style’ mutuals. That is, staff ‘buyouts’ of public sector provision using cooperative corporate structures. Such a model could also work in higher education. If such initiatives can offer degrees below the new £7,500 level, we should now see fewer ‘cons’ for such new ventures or for existing art departments to secede from whatever large institution they currently inhabit. The proposed changes to VAT (§1.20), exempting services shared across different institutions from this 20% surcharge, would enable independent operations to use those provided by more established universities at ‘arms length’ while benefiting from suitable economies of scale.

#8. The White Paper makes it less attractive to step outside of the regulatory framework.

Consider the University of Buckingham, which has operated as an independent university since its inception in the 1970s. It received no direct grant from the government for undergraduate teaching and so was able to operate outside the burden of administrative and bureaucratic structures dependent on such money. Prior to the publication of the White Paper, some vice-chancellors mooted copying that model to escape the tuition fee caps (AC Grayling’s New College of the Humanities is one such heavily criticised example) or the burdensome institutional recruitment caps.

However it is now clear that such a choice would preclude students at such institutions from accessing any public loan support provided through the government’s Student Loans Company. Independence of this kind – breaking tuition fee caps and recruitment numbers – would exclude access to this important resource. Unless an institution is able to set up its own equivalent arrangement with banks, it would be operating at a distinct disadvantage: being wholly reliant on wealthy students for its recruitment. The banking subsidiary Santander UK has admitted to conversations with David Willetts, Minister for Science and Universities, about such independent loan arrangements, but made it clear that it was only interested in financing students at Oxbridge and the Russell Group, since graduates of those institutions have on average better salaries and hence pay off loans more quickly.

However, a further option is sketched in the White Paper: the Government intends to consult on making it easier for established universities to change their corporate structure in order to facilitate access to private finance (§4.35). This could enable public universities to ditch charitable status and become, potentially, for profit enterprises. Some art and design institutions may consider this option.


#9. The Government is keen to encourage teaching-only institutions.

It is rumoured that large sections of the White Paper were left on the cutting room floor at a late stage and that these sections largely related to research. It is a glaring omission in a vision for higher education. A consistent theme, though, is to encourage teaching-only institutions, such as US liberal arts colleges, to promote the ‘student experience’, since the staff employed would not be ‘distracted’ by research activities. Currently, all staff on academic contracts in England have some research component, most typically 20% of their time. Moving an institution to teaching-only may be one way to cut such costs and may be an effective approach, as a promotional strategy (telling the government what they want to hear), in any bid for the low-cost pool of places. It obviously has big implications for staffing and current contracts.

Degrees: Foundation, Undergraduate, Postgraduate, Research

#10. The White Paper proposes powers to suspend or remove degree awarding powers.

The White Paper does propose new powers to ‘suspend or remove’ degree awarding powers ‘where quality or academic standards fail’ (see §4.32). There is an interventionist model proposed for quality monitoring through review:

§3.20 We will ask HEFCE to consult on the criteria against which overall risk should be assessed and the frequency of review, with a view to achieving very substantial deregulatory change for institutions that can demonstrate low risk. We will explore how the need for and frequency of scheduled institutional reviews will depend on an objective set of criteria. HEFCE will also consult on a set of ad hoc triggers which would prompt QAA to carry out a full or partial review when this was not otherwise expected. (my emphasis in bold)

This proposal has already been criticised for its cavalier formulation: at other places in the White Paper (e.g. page 10) it is suggested that ‘recent track record’ and ‘student satisfaction’ could ‘trigger’ such an investigation, with far graver consequences than the review recently conducted by QAA into London College of Communication . Institutions that have performed poorly in the National Student Satisfaction survey will perhaps need to worry about these results for reasons other than recruitment and marketing. Such worries do not reduce ‘compliance’ costs or ease the burden of regulation: staff should expect an increasing administrative load here.

I guess we can only conclude with a further question: what are we going to do about this?

Addendum: 24.10.2011

England’s higher education funding council and soon-to-be regulator, HEFCE, has now published its response to its consultation on student numbers controls for 2012/13.

Specialist institutions, such as music conservatoires and art and design colleges, will be able to apply for an exemption from the coming year. To be eligible to apply to opt out of the complex restrictions on student numbers, the institution must have more than 60% of their undergraduate places in media studies, design or the creative arts and recruit primarily on the basis of audition or portfolio.

This enables these institutions to avoid the problems outlined above in points #1–5. Their recruitment allocation will only be reduced by 2% but in return for this stability they will not be allowed to expand. That is, they suffer neither of the two main ‘slices’ – the top slice, achieved by removing a proportion based on the numbers of AAB+ students currently studying at the institution; the bottom slice of 8–9% that forms the competitive pool of 20,000 places.

Many art and design colleges will have students who hold the grades AAB+ but may not wish to change their recruitment practices in order to maintain current numbers, which they would do by targeting students with those qualifications. Most will be keen to avoid the vagaries of the competitive bidding process for the 20,000 places, which are reserved for universities whose average fees are below £7,500, and the necessity of dropping average fees below that amount. Alternatively some managements, possibly outside London and with relatively low current numbers, may feel in a strong position to expand and so decide not to opt out. Foundation degree places are eligible for the 20,000 pool so colleges offering such degrees may look to take advantage. (NCG – formerly Newcastle City Group – now has its own foundation degree awarding powers and may look to take advantage here.) The deadline for applying for an exemption is 11 November 2011.

Though this is good news for most art and design colleges, art and design courses, departments and faculties within other institutions are potentially at a disadvantage here. Since the number of places available in the core allocation is set at the overall level of institution, those within larger universities will not be eligible for an exemption. Instead, recruitment practices for 2012/13 will have to be negotiated with senior management in order to work out how portfolio and audition recruitment fits with the institution’s overall ‘core’. Staff and students should familiarise themselves with the current AAB+ ratios at institutional level and at departmental level. Official core allocations will be announced to institutions in January 2012 but provisional numbers can be calculated based on current data and HEFCE’s new methodology for determining core and margin.

This exemption is offered for 2012/13. It does not mean that the issue will not be revisited in future. Paragraph 54 of the HEFCE response reads:

‘We recognise that option 2 (applying to opt out) does not apply the same pressure on institutions to keep their average fulltime undergraduate tuition fees no higher than £7,500, which is an aim of the core/margin policy. However, we have been convinced by the case of institutions of this type having particular circumstances that cannot reasonably be addressed in any other way for 2012–13.’

Since this is the aim of the coalition’s white paper, the issue is likely to be revisited in a second stage of consultations on funding which commences in a few months time. This consultation will also review the direct grant to small and specialist institutions.

  1. I have co-written a response covering those points at Campaign for the Public University.

  2. All citations refer to the paragraph numbering in the White Paper.

  3. A-levels are the final examinations taken by English, Welsh and Northern Irish students who have elected to continue in education beyond the age of sixteen. Typically, each student will sit papers in the three or four subjects they have elected to study. Candidates receive a grade in each subject, with ‘A’ being the highest. The reduction will originally be determined by 2010/11 returns made to the Higher Education Statistics Agency (HESA).

  4. See for example the conference on ‘deschooling’ organised by the Hayward and Serpentine galleries in April 2010: http://en.wordpress.com/tag/deschooling-society/. Or, more recently, the discussion triggered by Mike Watson’s short article in Art Monthly 342, ‘Education Cuts Both Ways’, December 2010 /January 2011, p.39.