Student Awards Agency Scotland policies, guidance and statistics: FOI release

Information requested

SECTION A — POLICIES, PROCEDURES & GUIDANCE

1. Policies for DSA Travel Claims

All internal policies and guidance relating to:

• verification of taxi journeys
• acceptable evidence for cash taxi payments
• use of private hire or independent taxi providers
• evidence assessment criteria
• contacting external parties during verification

2. Counter Fraud Team Policies

All policies or guidance on:

• determining fraud vs insufficient evidence
• applying the “balance of probabilities” standard
• documenting decisions
• escalation procedures
• contacting third parties

3. Complaint & Appeal Handling Guidance (DSA-related)

All guidance used between 2020/21 and 2024/25.

4. Restricted Funding Policy

All current and previous versions (2020/21–2024/25) of the Restricted Funding Policy, including:

• criteria for sanctions
• partial vs full restriction
• maximum/reduced terms
• definition of “severity of the action”
• standard of proof
• authorisation levels
• guidance to panel members

5. Equality Impact Assessments

Equality Impact Assessments relating to:

• DSA travel processes
• fraud investigations
• the Restricted Funding Policy
• funding restriction decisions

SECTION B — STAFF TRAINING & OPERATIONAL MATERIALS

6. Training Materials

Training materials (2020/21–2024/25) provided to:

• Counter Fraud Team
• Complaints Team
• Case Handlers
• Senior Managers/Executives who handle complaints, Restricted Funding and appeals

Specifically including training on:

• DSA claims
• evaluating taxi evidence
• handling cash evidence
• fraud investigation
• sanctions under the Restricted Funding Policy
• disability and reasonable adjustments

7. Internal Manuals & Guidance

Any staff manuals or internal operational guidance relating to:

• fraud investigations
• restricted funding decisions
• Restricted funding sanctions panel processes

8. Guidance to cash paying DSA students

Any guidance issued to students relating to:

• How students should have an audit trail of their cash payments
• Specific criteria SAAS expect in order to accept a cash paying claim from a DSA student

SECTION C — STATISTICS & MONITORING (2020/21–2024/25)

9. DSA Travel Claim Outcomes

Per academic year:

• claims submitted
• claims approved
• claims rejected
• referred to Counter Fraud
• insufficient evidence determination
• fraud determinations

10. Taxi Verification Outcomes

Per academic year:

• cases rejected due to non-verification
• cases where cash receipts/withdrawals were accepted as evidence
• cases where cash receipts/withdrawals were rejected

11. Restricted Funding Register & Sanctions

Per academic year:

• students added to the register
• funding stopped (loan & tuition)
• discretionary funding stopped
• recovery action taken
• refusal of current-year reimbursements
• combined sanctions applied

12. Overturned Decisions

Per academic year:

• fraud decisions overturned after complaint
• fraud decisions overturned after appeal
• fraud decisions overturned after SPSO involvement

SECTION D — INTERNAL AUDITS & QUALITY ASSURANCE

13. Internal Audits or Reviews

All internal audits (2020/21–2024/25) relating to:

• DSA travel processing
• fraud investigation processes
• sanctions decisions
• restricted funding register

14. Internal Concerns

Any documented concerns, recommendations, or issues raised internally or externally relating to:

• Counter Fraud Team processes
• taxi verification
• staff training
• sanctions procedures

(I do not seek personal data about other students.)

SECTION E — SANCTIONS PANEL DECISIONS & APPLICATION OF GUIDANCE

For each academic year from 2020/21 to 2024/25, please provide:

15. Application of Restricted Funding Policy

Number of cases where:

• a partial restriction was applied
• a full restriction was applied
• the maximum 6-year term was applied
• a reduced term was used
• the sanction was limited to one element of funding
• multiple sanctions were applied simultaneously

16. Cases Where All of the Following Were Applied Together

Please provide counts per year of cases where SAAS applied the full combination of sanctions:

• stopping all living-cost support
• stopping tuition fee support
• blocking discretionary/hardship funding
• placing student on the restricted funding register
• requiring repayment of previous-year payments
• refusing reimbursement for current-year costs

SECTION F — EARLY PANEL CONVENING & REPRESENTATION RIGHTS

For each academic year (2020/21–2024/25):

17. Panel Timing

• number of cases where a panel convened within less than 2 weeks of notifying a student of the fraud determination (the two weeks the student is given in writing to make representations)
• number of cases where a panel convened before the student could provide representations

18. Representation Period Compliance

• number of students not given the full 2-week window
• number given less than 2 weeks
• number given no opportunity to provide representations

19. Timing Data

• the average time between fraud notification and panel meeting
• the shortest time recorded

Response

SECTION A — POLICIES, PROCEDURES & GUIDANCE

1. Policies for DSA Travel Claims

All internal policies and guidance relating to:

• verification of taxi journeys
• acceptable evidence for cash taxi payments
• use of private hire or independent taxi providers
• evidence assessment criteria
• contacting external parties during verification

The information relating to the above can be found online at Disabled Students' Allowance (DSA) - SAAS - Funding

2. Counter Fraud Team Policies

All policies or guidance on:

• determining fraud vs insufficient evidence
• applying the “balance of probabilities” standard
• documenting decisions
• escalation procedures
• contacting third parties

Details regarding Counter Fraud Policies can be found on the SAAS website Fraud Prevention - SAAS

3. Complaint & Appeal Handling Guidance (DSA-related)

All guidance used between 2020/21 and 2024/25.

Please note that from the start of academic year 2020-21 our complaint and appeals options were found on the Contact Us page here: Contact us - SAAS . The Complaints Handing Procedure used at that time was Complaints handling procedure.pdf.

On 27 May 2021 this information was amended to the information that is currently on our website here: A Guide to Complaints - SAAS and Appeals Guide - SAAS

4. Restricted Funding Policy

All current and previous versions (2020/21–2024/25) of the Restricted Funding Policy, including:

• criteria for sanctions
• partial vs full restriction
• maximum/reduced terms
• definition of “severity of the action”
• standard of proof
• authorisation levels
• guidance to panel members

Information regarding our Restricted Funding policy can be found on SAAS website at Restricted Funding policy

5. Equality Impact Assessments

Equality Impact Assessments relating to:

• DSA travel processes
• fraud investigations
• the Restricted Funding Policy
• funding restriction decisions

Please note any work on revised DSA Travel processes has been paused until the next steps of the Scottish Government Consultation on Support for Part Time Study and Disabled Students June 2025. Supporting documents - Education - support for part-time study and disabled students: consultation - June 2025 - gov.scot are published and developed.

Whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) cannot provide this information as this is exempt due to the development of Scottish Government policy.

Therefore, this is a formal notice under section 29 (1)(a) of FOISA.

SECTION B — STAFF TRAINING & OPERATIONAL MATERIALS

6. Training Materials

Training materials (2020/21–2024/25) provided to:

• Counter Fraud Team
• Complaints Team
• Case Handlers
• Senior Managers/Executives who handle complaints, Restricted Funding and appeals

Specifically including training on:

• DSA claims
• evaluating taxi evidence
• handling cash evidence
• fraud investigation
• sanctions under the Restricted Funding Policy
• disability and reasonable adjustments

Training materials have already been highlighted earlier in the response or are attached as a separate document. Please note that some of the information has been redacted as it refer to third party and they are

Our Counter Fraud Team undertake the industry standard qualification of Accredited Counter Fraud Specialist.

7. Internal Manuals & Guidance

Any staff manuals or internal operational guidance relating to:

• fraud investigations
• restricted funding decisions

Restricted funding sanctions panel processes

We are unable to provide you with this information under Section 35(1)(a): prevention or detection of crime. This exemption applies to the extent that complying would be likely to prejudice the proper discharge of the Counter Fraud Team’s function and ability to investigate potential fraud as this would provide the processes and procedures for doing so.

8. Guidance to cash paying DSA students

Any guidance issued to students relating to:

• How students should have an audit trail of their cash payments
• Specific criteria SAAS expect in order to accept a cash paying claim from a DSA student

Students are advised they can find guidance online on our website at Eligibility - Course eligibility

SECTION C — STATISTICS & MONITORING (2020/21–2024/25)

9. DSA Travel Claim Outcomes

Per academic year:

• claims submitted
• claims approved
• claims rejected
• referred to Counter Fraud
• insufficient evidence determination
• fraud determinations

Whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) does not hold the data broken down in the categories requested and would need to produce new data in order to get the information.

Therefore, this is a formal notice under section 17(1) of FOISA that the Student Awards Agency Scotland cannot provide the information as requested.

Under FOI legislation SAAS is not required to produce new data in relation to FOI requests.

10. Taxi Verification Outcomes

Per academic year:

• cases rejected due to non-verification
• cases where cash receipts/withdrawals were accepted as evidence
• cases where cash receipts/withdrawals were rejected

Whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) does not hold the data broken down in the categories requested and would need to produce new data in order to get the information.

Therefore, this is a formal notice under section 17(1) of FOISA that the Student Awards Agency Scotland cannot provide the information as requested.

Under FOI legislation SAAS is not required to produce new data in relation to FOI requests.

11. Restricted Funding Register & Sanctions

Per academic year:

1. students added to the register
2. funding stopped (loan & tuition)
3. discretionary funding stopped
4. recovery action taken
5. refusal of current-year reimbursements
6. combined sanctions applied

For parts 1 and 4 the information is as follows:

Year	Students added to the register	Recovery action taken
2020-2021	4	4
2021-2022	14	9
2022-2023	14	8
2023-2024	12	6
2024-2025	22	16

For parts 2, 3, 5,and 6 whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) does not hold the data in the categories requested and would need to produce new data in order to get the information.

Therefore, this is a formal notice under section 17(1) of FOISA that the Student Awards Agency Scotland cannot provide the information as requested.

Under FOI legislation SAAS is not required to produce new data in relation to FOI requests.

12. Overturned Decisions

Per academic year:

• fraud decisions overturned after complaint
• fraud decisions overturned after appeal
• fraud decisions overturned after SPSO involvement

The information provided below is from July 2024 when our new database was introduced.

Fraud decisions overturned after complaint: 0
Fraud decisions overturned after appeal: 0
Fraud decision overturned after SPSO involvement: 0

Whilst our aim is to provide information whenever possible, in this instance whilst the Student Awards Agency Scotland (SAAS) holds data for the earlier years it is not in the format you have requested and we would need to produce new data in order to get the information.

Therefore, this is a formal notice under section 17(1) of FOISA that the Student Awards Agency Scotland cannot provide the information as requested.

Under FOI legislation SAAS is not required to produce new data in relation to FOI requests.

SECTION D — INTERNAL AUDITS & QUALITY ASSURANCE

13. Internal Audits or Reviews

All internal audits (2020/21–2024/25) relating to:

• DSA travel processing
• fraud investigation processes
• sanctions decisions
• restricted funding register

Whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) cannot provide this information as this is exempt due to the development of Scottish Government policy.

Therefore, this is a formal notice under section 29 (1)(a) of FOISA.

14. Internal Concerns

Any documented concerns, recommendations, or issues raised internally or externally relating to:

• Counter Fraud Team processes
• taxi verification
• staff training
• sanctions procedures

(I do not seek personal data about other students.)

Whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) does not hold the data for the categories requested.

Therefore, this is a formal notice under section 17(1) of FOISA that the Student Awards Agency Scotland cannot provide the information as requested.

SECTION E — SANCTIONS PANEL DECISIONS & APPLICATION OF GUIDANCE

For each academic year from 2020/21 to 2024/25, please provide:

15. Application of Restricted Funding Policy

Number of cases where:

1. a partial restriction was applied
2. a full restriction was applied
3. the maximum 6-year term was applied
4. a reduced term was used
5. the sanction was limited to one element of funding
6. multiple sanctions were applied simultaneously

Year	2. Full restrictions	1. Partial restrictions
2020-2021	4	0
2021-2022	13	1
2022-2023	12	2
2023-2024	7	5
2024-2025	21	1

Whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) does not hold the data for categories 3,4,5 & 6 broken down in the in the format requested as there is no internal business requirement for this data and we would need to produce new data in order to get the information.

Therefore, this is a formal notice under section 17(1) of FOISA that the Student Awards Agency Scotland cannot provide the information as requested.

Under FOI legislation SAAS is not required to produce new data in relation to FOI requests.

16. Cases Where All of the Following Were Applied Together

Please provide counts per year of cases where SAAS applied the full combination of sanctions:

• stopping all living-cost support
• stopping tuition fee support
• blocking discretionary/hardship funding
• placing student on the restricted funding register
• requiring repayment of previous-year payments
• refusing reimbursement for current-year costs

Whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) does not hold the data for the categories, above, broken down in the in the format requested as there is no internal business requirement for this data and would need to produce new data in order to get the information.

Therefore, this is a formal notice under section 17(1) of FOISA that the Student Awards Agency Scotland cannot provide the information as requested.

Under FOI legislation SAAS is not required to produce new data in relation to FOI requests.

The information relating to the ‘blocking discretionary/hardship funding’ is administered by Higher Education Institutions and not by SAAS.

SECTION F — EARLY PANEL CONVENING & REPRESENTATION RIGHTS

For each academic year (2020/21–2024/25):

17. Panel Timing

• number of cases where a panel convened within less than 2 weeks of notifying a student of the fraud determination (the two weeks the student is given in writing to make representations)
• number of cases where a panel convened before the student could provide representations

Whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) does not hold the data for the categories, above, broken down in the in the format requested as there is no internal business requirement for this data and would need to produce new data in order to get the information.

Therefore, this is a formal notice under section 17(1) of FOISA that the Student Awards Agency Scotland cannot provide the information as requested.

Under FOI legislation SAAS is not required to produce new data in relation to FOI requests.

18. Representation Period Compliance

• number of students not given the full 2-week window
• number given less than 2 weeks
• number given no opportunity to provide representations

Whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) does not hold the data for the categories, above, broken down in the in the format requested as there is no internal business requirement for this data and would need to produce new data in order to get the information.

Therefore, this is a formal notice under section 17(1) of FOISA that the Student Awards Agency Scotland cannot provide the information as requested.

Under FOI legislation SAAS is not required to produce new data in relation to FOI requests.

19. Timing Data

• the average time between fraud notification and panel meeting
• the shortest time recorded

Whilst our aim is to provide information whenever possible, in this instance the Student Awards Agency Scotland (SAAS) does not hold the data for the categories, above, broken down in the in the format requested as there is no internal business requirement for this data and would need to produce new data in order to get the information.

Therefore, this is a formal notice under section 17(1) of FOISA that the Student Awards Agency Scotland cannot provide the information as requested.

Under FOI legislation SAAS is not required to produce new data in relation to FOI requests.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

FOI 202500493969 - Information released - Annex

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