CONSULTATION QUESTIONS
In order to bring budgetary responsibility closer to the decision making process:
1. Do you agree that budget responsibility should be devolved from SAAS?
No
The premise for the proposed changes, that there is a ‘disconnect between these professional assessments and the budget that supports the scheme’
is correct, but contrary to the view that this is a negative position and the basis for change, we believe that this is desirable.
The significant national rise in DSA spending in response to increased disability disclosure and consequent increased applicant eligibility is acknowledged; however the assumption that bringing budgetary
responsibility closer to institutions will bring faster turnarounds following assessments is conjecture and has no evidence base.
A more robust approach to the substantial change suggested may be to establish a short-life task group to analyse the current position and provide actual data, these results may better inform any alteration in current
administration of budgetary responsibility and/or other aspects of DSA.
1.1 If you disagree, what are the disadvantages?
It is highly unlikely that individual institutions will have equivalent capacity to manage and deliver substantial DSA budgets leading therefore to a
potential inequality of service to students and not the ‘no apparent change in service delivery’ as assumed in the proposal.
It is unclear from the proposals which University department or service is anticipated to take on any devolved budgetary responsibility though it is likely that in many institutions it may be a role assigned to the Disability Service. Disability Services, as currently resourced, are already stretched to meet the increasing needs of ever higher disabled student numbers and it untenable for them to take on additional devolved budgetary responsibility.
To take on this responsibility, institutions will require to recruit specialised additional staff, devise system processes, develop robust and auditable accounting procedures and subsequently deal with daily operational management. This will be costly and unnecessary as in doing so,
institutions will replicate what SAAS does already. It is difficult to see the justification for this.
The presence of SAAS as the awarding body and arbiter of the public purse, affords institutions and their DSA Assessors a buffer between the DSA applicant and the institution. Most experienced DSA Assessors
encounter instances of excessive student expectation and pressure from students and their families to upgrade recommendations. By maintaining SAAS as the awarding body the accurate perception that the funding source is the Government and funding allocation is subject to national parameters and constraints is upheld.
SAAS, as a centralised body, maintains a national perspective on DSA awards and is thus in a position to apply consistency in the application of standards. The DSA budget annually supports awards to high numbers of continuing students applying for continuing funding as well as to numerous first time applicants. Having a centralised body facilitates consistency of award throughout the entire student body, ensuring standards for
equipment, non-medical personal help and consumables are appropriately met for all applicants. Without this centralised body, a system where each institution determines how to disburse their individual DSA budget could very soon lead to variations in provision between institutions. Should this occur, differential provision may become a basis for complaints from students and their families.
At the moment, there is no cap on the overall DSA budget but if budgets are devolved to institutions the situation changes as budget controllers will be working with finite amounts. It is inevitable that the recommendations for student support provision as currently identified will be influenced by this.
It is unclear from the proposals how the DSA budget for each institution will be calculated. For smaller institutions this is of concern triggered by the fact that when Disability Premium Funding from the Scottish Funding Council was reviewed, the allocation to smaller institutions, often the very
institutions sought by vulnerable students, was very significantly reduced.
Total DSA funding that is sufficient to meet student needs is increasing year on year with some alteration on an annual basis as applicant numbers fluctuate and/or where individual students have extremely high support costs. It is difficult to see how a mechanism to determine institutional budgets can be devised simply and without constraint.
Currently DSA funding focuses entirely on awards to individual students, but with devolved budgetary controls, this core element of the DSA may be compromised. To remain within budget, institutions may have to consider alternatives to individual support, such as the FE model whereby Extended Learning Support provision for individual students can generate Student Units of Measurement and additional funding. Funding in this model is provided to the institution and often used to provide centralised staffing and resources. Thus the fundamental, valuable and central principle of
individual support provision via DSA is lost.
Devolved budgetary control may also make use of ‘ring-fencing’ of DSA funds whereby the total budget would have to be exclusively retained within an institution solely for that purpose, however budgetary pressures may make this difficult to maintain.
There is no mention in the proposals of how the DSA process will be applied to Scottish students studying outside Scotland, thus the consistency of award as currently overseen by SAAS may be compromised.
1.2 If you agree, what are the advantages?
No response is offered here.
Access Centres provide an important safety net in terms of non-validated institutions or institutions that are, for whatever reason, unable to carry out Assessments.
2. If budget responsibility is devolved, how would this reach the Access Centres?
Currently, QMU is validated as an accredited institution to conduct DSA Needs Assessments for students with Specific Learning Difficulty, Mental Health Difficulties and with Autistic Spectrum Disorders. We are reliant on working with the local Edinburgh College Access Centre to provide DSA Needs Assessments for students who do not fall into these categories such as students with sensory impairments, physical difficulties and a myriad of medical conditions.
It is of paramount importance that Access Centres are retained as fully functioning assessment centres where specialist provision, beyond the resources of individual institutions can be facilitated.
We have a lot of evidence in terms of historical spend, but future spend predictions are obviously more difficult. Any system of budget allocation would need to be flexible enough such that support could be provided for the unexpected or the exceptional.
3. If a budget was to be devolved how should this budget be set?
Ideally, there will be no devolution of budgetary control.
If budgets were to be set, it would probably be best based on previous total annual allocations, but it would be essential that the facility to access extra funding was available should an initial allocation prove inadequate either due to an unforeseen rise in applicant numbers or exceptional cases where very high funding awards to individuals are appropriate.
Alternatively a means of basing budgets on historical allocations and including an additional percentage of spend to be used if required and retained for a subsequent academic session could be established.
Some have expressed concerns around any budget provided to an institution for the purposes of supporting students with a disability being available for other aspects of learning.
4. Within an institution, would it be necessary to protect (ringfence) budgets allocated for the purposes of supporting students with a
disability? Would it be necessary to stipulate that budgets could only be used to support students and not to e.g. meet staff costs or other
‘reasonable adjustments’.
As providers of the budget, the Scottish Government needs to set any budgetary stipulations.
It is of concern however that the proposals do not include any mention of whether or not SAAS will continue to require the submission of DSA Needs Assessment Reports. Many institutions, including QMU, rely heavily on income generation from the provision of DSA Needs Assessments (circa
£400.00 per report) and individual assistive technology training (circa
£45.00 per hour) as the foundation for staffing costs. It can be argued that the rigorous validation process which currently underpins high quality needs assessment reports will, become redundant as in depth reports would become unnecessary. If these funding streams are to be lost, separate funding will be required to adequately resource Disability Service related posts.
The provision of reasonable adjustments for example network software is probably a cost that should be met by individual institutions as part of their commitment to the provision of an inclusive learning environment for all students, including those who are not eligible for DSA support, but who have additional support needs.
We expect the demands to continue to increase. Thus far, budgets have been increased retrospectively in order to meet increasing demand as it becomes apparent.
5. Devolved budgets would be set in advance. How would budgetary increases be negotiated?
Devolved budget increases should be negotiated annually by the institution and the Government. Evidential data required to underpin negotiations should be clearly established to ensure timely compilation.
As above, there would need to be some flexibility in recognition that budgets set in advance could not take account of exceptional demands.
6 What sort of safety net would be required in order to support institutions dealing with exceptional cases? e.g. A scheme developed along the lines of Discretionary Fund allocations with in-year re-distributions?
Retention of a top-slice by SAAS with a view to further demand-led allocations?
It is difficult to determine the kind of safety net required for exceptional cases as costings will probably alter year on year.
The Discretionary Fund led model is not favoured as this model requires action and agreement that is committee led. It may be difficult within institutions to find a broad range of staff who also have sufficient insight into the needs of disabled students to be able to make appropriate decisions.
Use of this model would probably necessitate the sharing of sensitive individual information regarding student circumstances with implications of breaching the Data Protection Act. There is also a concern that where a committee is making a decision, a compromised consensus decision may have to be determined with implications for constrained support that is not in the best interest of the student.
Retention of a top-slice by SAAS with a view to further demand-led allocations may be more appropriate.
It would be helpful if these alternatives were included in a pilot project so that the most appropriate can be better determined by appropriate analysis.
7. Are there aspects of this proposal that would justify a pilot approach, i.e. running “local budgets” at one or two sites alongside the traditional SAAS model for a period? Or is this proposal straightforward enough that it could be introduced universally from the start?
Yes.
Currently there are too many unknown elements of the proposed changes and of the challenges any implementation of change will make. If a pilot approach was taken, it would quickly indicate what processes and procedures were appropriate, identify any weaknesses in these and revise as needed.
Information related to best practice could be shared throughout the sector to assist the better understanding and smoother introduction of any proposed changes.
8. Support for students with a disability studying at the FE level is already administered locally. Is there a crossover here which means that
institutions where this already happens are already well placed to include HE support in their local budgetary arrangements?
This response is best answered by FE institutions. No response is offered here.
9. In the event that budgetary responsibility was devolved, what would be the ongoing role of SAAS / Scottish Government, e.g. continuation of the Validation Panels? monitoring standards of assessment? handling appeals?
It is essential that SAAS/Scottish Government continue to be have a major role in ensuring overall consistency of DSA support provision.
Validation Panels are key to ensuring that good practice is conducted nationwide and their work should continue. Validation panels are very well placed to monitor standards of needs assessments, being staffed in part by highly experienced practitioners. It would not be appropriate for SAAS to take over this role as many of their staff though currently key administrators of the DSA process lack professional insight into the conduct of actual assessments and in-depth knowledge of the Toolkit for Quality Indicators which informs the DSA Assessment Process.
The use of Validation Panels is currently a very Scottish model of quality assurance. The value of this model is currently being more widely recognised as an example of good practice and is being considered by the UK Government Department of Business, Innovation and Skills as they review quality assurance in England and Wales. This further supports their retention in favour of becoming a role for SAAS.
SAAS should also remain as an adjudicator in any appeal or complaint regarding the DSA process. Being one-step removed from institutions, having a national overview and being part of the Scottish Government brings impartiality and authority to decision making in such circumstances.
10. If a change to the way that budgets are managed was introduced, when do you think this should take effect from?
Non devolution of budgetary responsibility continues to be the preferred option.
If administrative changes are to take place, a significant lead time will be required to allow institutions to plan and resource changes. This will vary between institutions, but will require at least a full academic session for planning and resourcing and at least a year to pilot new processes and procedures.
An initial pilot project running in conjunction with a short-life task group may be appropriate in preference to nationwide change.
