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Submission - CEHA Government Plan 2022-25 Review - Jersey Student Loans Support Group - 9 November 2

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Government Plan 2022 Review - Children, Education and Home Affairs

Dear Panel,

The concerns of our group are that despite there being mention of consultation of the revised higher education grant, so far we have seen nothing even though we have frequently chased this for the past couple of years.

We note that the plan was to review before the end of 2021, any proposal needing to be debated by the assembly in order it would be in place for the academic year 2023/24, giving sufficient time for parents and students to plan ahead. We had confirmed this with the minister recently.

The minister told us that officers were due to present the options, and he was taking that to the CoM for a decision.

It wasn't until your meeting with the minister 1st November, that he mentioned it is to be an RPI adjustment which came as a surprise.

There is no detail of what the RPI adjustment will be.

We note that yet again postgraduate funding is still being discussed, we would like to remind the panel that this has not been reviewed for as far as we are aware, 21 years, and exists as a bursary largely unchanged.

Not all postgraduate funding has been left, as any that come in under the grant scheme is reviewed, this is an unfair situation.

We would remind the panel that the removal of the HCA included all students on all higher education courses. Therefore those who do not get a bursary, or do not come under the undergrad scheme have been further disadvantaged.

They have even less support than they did.

We also noted that the panel had asked the minister and officers about the ministerial order which has been put in place until 2022 in the panels minutes of the 10th September.

This is a big concern to parents, it would seem that the scheme has not been applied according to the regulations.

The cost of this was not given and is not mentioned in your minutes.

The cost even for one year if it applies to the lowest amount a grant can alter by £1500 is £495,000 per year on the number of students quoted (330).

If however it was the total amount of grant £16,750 the cost rises to

 £5,527,500. This can happen where a parent of a student has income above the threshold or who has assets of £500,000 and therefore excludes any grant award.

We expect then that the figure must lie somewhere between these two. We have no idea how long this error has been going on for.

For our group of parents and students it is seen as unfair for some, and unfair for others depending on the marital status and living arrangements of parents.

What is very clear is that this section of the regulations have been in place for a considerable period of time.

EDUCATION (DISCRETIONARY GRANTS – GENERAL) (JERSEY) ORDER 2001

(a) the income of the student's parents for the calendar year preceding the academic year;

In 2007, in force 2008.

The relevant income in respect of a dependent student for an academic year is the

income of the student's parents for the calendar year preceding the calendar year in which the academic year commences.

Checking later amendments the addition of using a relevant person in the calculation was more recent in 2013.

https://www.jerseylaw.je/laws/enacted/Pages/RO-109-2013.aspx

For some to have to have two incomes used, but others not to because one parent lives in another household seems to be what has been applied, rather than correctly the income of the student's parents which would be two incomes as in the regulations.

Since the MO and as the regulations have been incorrectly applied as follows:

 It can be chosen whether a relevant person's income is used or the student's other parental income is. Creating another inequality, as they will likely chose the one to give the best grant award, it makes no difference to the parents or relevant person, other than their own arrangements to fund the student should they chose to.

A family where the two parents live together must have both incomes.

A family where the other parent lives in another household only uses one income, the one the student lives with. No reasoning has been given as to why the other parental income in this situation has not been used, the parent may or may not provide maintenance payments for the student or other financial support.

The minister has exceptional circumstances in the regulations that can be applied or if it is seen as unfair to the student. Mention was made of the staffing requirements needed to do this. No mention was made of the cost of not doing, or doing this. It would be difficult to see how staffing cost would exceed £495,000 per year.

The ministerial order this year as we understand it has formalised how the regulations have been incorrectly applied, and are for 2021/22 only.

The people who are affected by this is the students, they have no control over parental income.

They see other students who have the same parental income but due to the nature of living arrangements and application of the regulations have different grants, it can be a huge difference, or very small. This does seem unfair.

As regulations are checked for human rights compliance we can only assume that the regulations as written originally do comply. However, we are unsure if changes by ministerial order are given the same scrutiny?

We do not know if the funding in the government plan is based on the regulations as was written, or if it has been based on how the department have applied it; we don't know how long this has been misapplied and if the budget assumptions are based on that.

We would like to see good clear information provided on which incomes are to be used as soon as possible, students have already made applications and parents need to know on what basis grant awards will be made.

Considering the sums involved even at the smallest figure it is significant in a department that is running a deficit.

In the minutes:

"It was highlighted that the Order would ensure that nothing would change for students until 2022. It was explained that in the interim a conclusion would be reached on how to progress going forward. It was explained that work regarding that would be undertaken within the next few weeks."

Considering that this meeting took place almost two months ago, we have not been told of any results of this work.

It maybe the panel has more recent information, than our group the users of the system, and students the beneficiaries.

We would like to also make the following points which we had hoped would be included in a review and naturally effects the cost of the scheme, and the government plan;

That the maintenance grant that is currently given was largely the same under the old scheme, and has been for the life of the current scheme which is now two years over it's intended review date as agreed by the assembly.

We would expect the RPI to be calculated based on the start of the current scheme figure at the minimum, and ought to be reviewed each year.

The cost of student accommodation in the U.K. has outstripped the U.K. RPI. consistently for years. Evidenced from the NUS Unipol surveys.

We ran a small survey ourselves this year a copy was sent to the panel, and the department.

We are in danger again of reducing the numbers of students that can go on to higher education if it becomes unaffordable for families and students.

We would remind the panel that dependent students studying on island receive exactly the same amount of grant as one studying off island does.

The costs between the two are very different.

The island does not provide the choice of courses that is offered off island, and is unlikely to be able to do so. Some will always have to study off island.

The step changes in the maintenance grant causes problems. If a parent works one hour of paid overtime it can mean a student loses £1500 of funding.

This isn't easily made up by lower income families, and or students who have to find the time whilst studying to cover that loss by working longer hours usually on minimum wage.

It is unclear to us now if there will be a review at all, if there is, the government seems to have already decided without consultation with users.

It has become very clear that the lack of staffing has impacted students and their parents for a few years. Some is due to covid and the restrictions that has caused.

Grant award letters sent to some only after they have gone away. As mentioned previously to the panel this cause a great deal of anxiety and can be catastrophic if a student finds out they are ineligible for a grant, when they have signed contracts for a course and accommodation.

Stress is caused if students, particularly first year, have not received their grant payment and receive requests from the universities for hall payments, or private rents that they can't afford to pay.

Unmanned phones, and no replies to emails from the department does not help their anxiety, when under such pressure to supply a date for when rent payments can be made. Parents are equally stressed.

We expect the staff similarly find it difficult dealing on a daily basis with frustrated parents and students.

The issue we see is one of volume of applications to process, in a short period of time when results come out, the department needs more staff at these pinch points to answer queries and send out grant award letters.

We have as admins of this group answered some queries where we can, but it should not be for a group such as ours to do this. It is the responsibility of government to provide services to the public, which taxpayers are funding.

We have worked with the student finance team to try an alleviate some of the common problems, normally caused by parents and students not understanding the process and what information they need to give and when.

The information of the process is there on the website, however some of the forms are not, and need to be requested.

What is needed is an updated system that generates an email prompting the next piece of required information, or better, an account where students can check the process of their grant with prompts for missing information/ next step and a required date.

Unless steps are taken to provide adequate staffing, or an IT system that would reduce the workload, we can't see how the situation will improve.

We looked at other changes this year and that is Independent Taxation, whilst it doesn't change the grant awarded, what it does do by the nature of it coming in by groups over a period of years mean that by changing which of a couple have allowances, and if that is done in a certain way the disposable incomes of some families notably those on higher incomes creates some unfairness.

We were glad to have the opportunity to discuss this with the Comptroller recently and highlight that tax changes, and changes to areas like Income Support, and Social security benefits have indirect impacts elsewhere tgat need to be considered.

It would be accurate to say both our group, and the student finance team would never like a repeat of the impacts of the HCA removal and trying to explain how it worked and the implications on the student grant and the parents ITIS rate ever again.

Whilst this is outside of the scope of the scrutiny of a government plan, it is an area which can cause extra costs, and staff time and one we would raise in consultation and / or review, should it ever happen.

Yours Sincerely N. Heath

Student Loan Support Group