Saturday 23 June 2018

Levitate Student - Postgraduate Pre-registration NHS Students

Postgraduate Pre-registration NHS students were added to Education (Student Support) Regulations 2011 by an amendment made back in February - this made it appear that they would be funded going forward in a similar way to Postgraduate Certificate in Education students in the form of loans and grants rather than NHS bursary. 

There was a bit of jiggery pokery when the regulation were revoked so the shift in funding could be debated in parliament but then the amendments to the regulations were reinstated.

So it's loans and grants for these students going forward. 


We wondered if the maximum fee should be £9,250 in line the other courses which fall under the Education (Student Support)Regulations 2011 .

A scan of university websites showed that there seemed to be some still advertising much higher fees for these courses. 

We have clarified this with Office for Students and Dept for Education the former replied thus.....



The distinction between students’ eligibility for student support (including tuition fee loans) and whether or not students are subject to regulated tuition fee caps is correct.

On fee caps, for 2018-19, we are still operating under the system that applied under the Higher Education Act 2004 (http://www.legislation.gov.uk/ukpga/2004/8/contents).

Compliance with fee limits is a condition of grant, under Section 24, which makes provision for this condition to apply in relation to qualifying courses and qualifying persons etc. The reason postgraduate pre-registration courses are not covered is a consequence of Section 41(1), which begins:

41 Interpretation of Part 3
(1)In this Part—

This does not change from 2019-20. Enforcement of regulated tuition fees will be a condition of registration under Section 10 of the Higher Education and Research Act 2017 (http://www.legislation.gov.uk/ukpga/2017/29/contents/enacted). Section 10(9) begins:


(9)In this section—
  • “higher education course” does not include any postgraduate course other than a course of initial teacher training;



  
Department for Education said this... 

Higher Education and Research Act 2017

Part 1 of HERA 2017 covers the Office for Students and includes the mandatory registration conditions:

Section 10 covers mandatory fee limit conditions for certain providers (those in the Approved (Fee Cap) category).

Section 10(3) of HERA stipulates the following: ‘“Regulated course fees” are fees payable to the provider by a qualifying person—

(a) in connection with his or her undertaking a qualifying course, and
(b) in respect of an academic year applicable to that course which begins at the same time as, or while, the provider is registered in the register.’

Section 10(6) of HERA stipulates the following: ‘A “qualifying course” means a higher education course of a prescribed description.’

Section 10(9) of HERA stipulates the following:  ‘In this section—
.
“higher education course” does not include any postgraduate course other than a course of initial teacher training;
“prescribed” means prescribed by regulations made by the Secretary of State for the purposes of this section.’

It follows therefore that postgraduate healthcare courses are not subject to fee caps under HERA 2017 for 2019/20.

So student loans are available to replace NHS Bursaries but courses are not subject to the fee cap of £9,250. This means that a student could apply for the maximum fee loan of £9,250 while the institution could charge them more if they wanted. That said this document from the Office for Students indicates a financial compensation given to the universities per head of post-graduate pre-registration NHS student on a course. However given the fees usually charged for these courses are in the region of £13,000 the amount of compensation per head seems to fall short of what the universities might argue they need.