Higher education - re-committing to Fair Access - a plan for recovery: annual report 2021

The fourth annual report of the Commissioner for Fair Access to higher education celebrates the progress that has been made and warns about the impact of the COVID-19 emergency, and the resulting setback to achieving fair access.

2. The Commission on Widening Access – Five Years On

The establishment of the Commission on Widening Access (COWA) chaired by Dame Ruth Silver in 2014 was a key intervention in the drive to produce fairer access to higher education. The Commission published an interim report in November 2015 and its final report in March 2016. The fifth anniversary of this final report offers an opportunity for stock-taking, in particular to review:

  • the overall progress that has been made;
  • COWA recommendations that have been fully and partially implemented;
  • recommendations that have yet to be implemented (whether because of the difficulties of implanting them, lack of a will to do so, or because circumstances have changed);
  • and any new recommendations that need to be made in the light of changing circumstances (the Covid-19 emergency is the most obvious example) or new priorities.


The remit of the Commission was rooted in the 2014-15 Programme for Government, and its ambitions to make Scotland a fairer society. Its remit was: 1. to develop a shared understanding of the challenges of fair access; 2. to set clear targets; and 3. to help develop a culture of partnerships including early years, schools, colleges, universities, employers and Government. To fulfil this remit COWA was asked: 1. to synthesise the evidence about un/fair access; 2. to suggest short- and long-term targets; 3. to identify best practice; and 4. to identify data and information requirements.


The COWA report was warmly received. A little over a year later in May 2017 the then Minister for Further Education, Higher Education and Science made a statement to Parliament endorsing the key messages of the report and reporting on progress towards implementing its most important recommendations. The statement identified eight 'foundational recommendations'. Universities Scotland shortly afterwards (October 2017) produced its own report Working To Widen Access, based on its three work streams – on admissions, articulation and bridging programmes. This report focused on the 15 recommendations directly addressed to or most relevant to universities. More recently regular monitoring reports have been made to the meetings of the Access Delivery Group, although the group has not met since 2019 because of the Covid-19 emergency. Progress towards implementing key COWA recommendations has also been reviewed in the annual reports of the Commissioner for Fair Access.


The Commission made 34 recommendations, which are listed below. I have included my assessment of the state of play with regard to each. 'Foundational' recommendations are in bold (1, 2, 3, 11, 12, 21, 22 and 32).

Recommendation 1

The Scottish Government should appoint a Commissioner for Fair Access by the end of 2016 to:

  • lead cohesive and system-wide efforts to drive fair access in Scotland, acting as an advocate for access for disadvantaged learners and holding to account those with a role to play in achieving equal access;
  • coordinate and prioritise the development of a more substantial evidence base on the issues most pertinent to fair access, including the commissioning and publication of independent research (the Scottish Government should ensure an appropriate annual budget is made available to support this work), and;
  • publish, annually, a report to Ministers outlining the Commissioner's views on progress towards equal access in Scotland to inform development of effective policy at national, regional and institutional level.

This recommendation has been implemented in part. A Commissioner for Fair Access was appointed in December 2016. Three annual reports have been published, and the present report is the fourth. In addition an interim report on the impact of Covid-19 on fair access was published in December 2020. But the Commissioner was not allocated an annual research budget. It was decided by the Government and the Commissioner jointly that the Commissioner would not be in the position to manage a research budget without a supporting administrative structure, the provision of which might undermine the independence of the role. As a result independent research has not been commissioned, although the need to address the evidence base has been addressed by publishing six Discussion Documents that bring together the most up-to-date statistics on key issues related to fair access with a commentary by the Commissioner.

The other 33 recommendations were grouped under 20 headings:

Identifying and Sharing Good Practice

Recommendation 2

By 2018, the Commissioner for Fair Access, working with experts, should publish a Scottish Framework for Fair Access. This authoritative, evidence-based framework should identify the most impactful forms of access activity at each stage of the learner journey, from early learning through to higher education, and provide best practice guidelines on its delivery and evaluation.

This recommendation has been implemented, although issues of longer-term sustainability remain. The Framework for Fair Access was established in June 2019, comprising two pillars – an online toolkit containing evidence and evaluations of good practice, and the establishment of the Scotland's Community of Access and Participation Practitioners (SCAPP). A Framework Governance Group, now chaired by the Commissioner and bringing together key stakeholders, has met on four occasions. Funding for both pillars was provided on a time-limited period by the SFC. However, it has proved difficulty to attract bidders to take on the maintenance and updating of the toolkit, in part because of the disruption arising from the Covid-19 emergency which arose less than a year after the launch of the Framework. Nor is permanent funding yet in place. A more extended discussion of the future of the Framework is included in the final section of this Annual Report.

Recommendation 3

Public funding for access programmes – either through specific external funding or funding from core budgets – should focus on programmes that are consistent with the Scottish Framework for Fair Access.

This recommendation has not been achieved. The Framework for Fair Access is not yet established on a secure enough footing to act as template for all public funding of access programmes, even if that was desirable. In my view, even when the Framework is more firmly established, it should be regarded as reference point to inform funding priorities for access programmes rather than a rigid template to ensure that all programmes are fully 'consistent' with the Framework. It is important to leave room for innovation and also important to respect the autonomy of institutions to set their own priorities. As it has developed, the Framework has been designed as a tool that practitioners can use rather than as an authoritative template.

Coordinating the Delivery of What Works

Recommendation 4

Universities, colleges, local authorities, schools, SFC-funded access programmes and early years providers should work together to deliver a coordinated approach to access which removes duplication and provides a coherent and comprehensive offer to learners. This should include the development of mechanisms by which access programmes undertaken in one institution, or in one part of the country, can be recognised by other institutions, while also serving institutional and local needs. Credit rating on the SCQF Framework should be considered where appropriate.

This recommendation has not been implemented as such. Although it is clearly important to reduce duplication and provide a more coherent and comprehensive offer, before the recommendation could be implemented in a meaningful way there has had to be a more concrete expression of how these – highly desirable – outcomes can be achieved. A number of bodies has been established to bring together a wide variety of stakeholders, including the Access Delivery Group chaired by the Minister and the SFC's Access Programmes Advisory Group and Bridging Programmes Advisory Group. Universities Scotland also established three working groups – on admissions, articulation and bridging programmes. There are clearly dangers in the proliferation of such bodies (and of acronyms understood only by insiders). But they have served a valuable purpose by allowing key actors to familiarise themselves with each other – and each others' agendas – especially across sectoral boundaries. Although progress has been made on a regional basis, the full portability and recognition of access programmes on a national basis remain to be achieved.

The review of SFC-funded access programmes is not yet complete. As a result forward funding has not yet been confirmed. Funding these programmes on a project basis is not satisfactory. Without longer-term funding their role in embedded institutional strategies could be at risk.

Flexible Transitions

Recommendation 5

Universities should ensure their admissions processes and entry requirements are based on a strong educational rationale and are not unnecessarily prescriptive, to the detriment of learners who take advantage of the availability of a more flexible range of pathways. This should be monitored by the SFC through the outcome agreement process.

Recommendation 6

The Scottish Government, working with key stakeholders, should ensure the key transitions phases around SCQF levels 6 to 8 are better used to provide students from disadvantaged backgrounds with the qualifications and experiences required to support fair access.

These recommendations have been partly implemented. The Government established a review of the Learner Journey 16-24, which was an attempt to identify (and, ideally, coordinate) the various pathways – in further and higher education and also work-based training – open to young people.

The follow-through of this promising initiative has been limited – so far. A Covid-19 Learner Journey Taskforce was established in January 21 and has met on three occasions. Unsurprisingly its focus has been on the immediate issues raised by the Covid-19 emergency rather than addressing wider issues with regard to transition and articulation and building a better-integrated tertiary education and training system. The focus of the Taskforce, as of the Learner Journey initiative, was not solely on young people from disadvantaged backgrounds, although the development of more flexible pathways through tertiary education and training is likely to benefit them more than more advantaged young people with more settled and traditional trajectories.

Universities have indirectly addressed Recommendation 5 in the course of their work on minimum entry requirements (MERs) and contextual admissions, and on articulation. The SFC has not monitored this recommended requirement through outcome agreements. As the direction of travel in the SFC's sustainability review is towards less detailed agreements, it seems unlikely to do so in future.

Bridging Programmes

Recommendation 7

The Scottish Funding Council, working with professionals, should develop a model of how bridging programmes can be expanded nationally to match need.

This recommendation has only been partly addressed. The SFC established a Bridging Programmes Advisory Group (see recommendation 4), which had begun to do useful scoping work before the Covid-19 emergency. Universities Scotland also established a Bridging Programmes Working Group. The SFC has also provided initial funding for the Scottish Framework for Fair Access. But a model for bridging programmes that can be applied nationally is still far off, and the principle that such a standard model would even be desirable is not yet generally accepted.


Recommendation 8

The SFC should seek more demanding articulation targets from those universities that have not traditionally been significant players in articulation.

Recommendation 9

Universities, colleges and the SFC should closely monitor the expansion of articulation to ensure it continues to support disadvantaged learners to progress to degree-level study. Should this not be the case, a proportion of articulation places should be prioritised for disadvantaged learners.

Recommendation 10

The Scottish Funding Council, working with universities and colleges, should explore more efficient, flexible and learner-centred models of articulation which provide learners with the choice of a broader range of institutions and courses.

Progress on implementing these three recommendations has been slow. The SFC has encouraged universities to give advanced standing to more Higher National entrants, and set a target of 75 per cent of transferring HN students being granted advanced standing, ie full credit, by 2026. But the majority of articulating students are still admitted by particular universities – 'post-1992' universities, Strathclyde and Heriot-Watt, although other 'pre-1992' universities such as Dundee and Stirling have made considerable efforts – and in particular subjects, especially business and administrative studies, computing and engineering.

Universities Scotland established an Articulation Working Group as one of its post-COWA work streams, which was disbanded in September 2017 when its world was complete. The National Articulation Forum was then set up jointly by Colleges Scotland and Universities Scotland. The National Articulation Forum produced its first report in 2020. But the report was limited in scope – and, indeed, focused on 'scoping' in terms of investigating student views, mapping HN and degree curricula and improving information. The work of the Forum continues. A national articulation database has also been developed. Dedicated pathways between individual colleges and universities have been developed. But outside these pathways HN students continue to be regarded as, essentially, 'non-standard' entrants compared with those with traditional academic qualifications. Overall there is no evidence of the step change in the approach to articulation recommended by the Commission.

Access Threshold for Admissions

Recommendation 11

By 2019 all universities should set access thresholds for all degree programmes against which learners from the most deprived backgrounds should be assessed. These access thresholds should be separate to standard entrance requirements and set as ambitiously as possible, at a level which accurately reflects the minimum academic standard and subject knowledge necessary to successfully complete a degree programme.

Recommendation 12

All universities should be as open and transparent as possible over their use of access thresholds and wider contextual admissions policies. In particular, they should seek to maximise applications from disadvantaged learners by proactively promoting the access thresholds to the relevant schools, pupils, parents, local authorities and teachers.

Welcome progress has been made towards implementing these two recommendations. The report of Universities Scotland's Admissions Working Group Working to Widen Access laid the groundwork on minimum entry requirements, which are now published by every university for all universities, a significant advance in terms of transparency. In my view these have not always been 'set as ambitiously as possible'. But I recognise the challenge faced by universities in carrying the wider academic community with them in setting access thresholds that reflect the attainment and knowledge necessary to successfully complete degree courses.

Recommendation 13

The Commissioner for Fair Access, should engage with those compiling key university rankings to ensure greater priority is given to socioeconomic diversity within the rankings and to ensure that institutions who take the actions necessary to achieve fair access are not penalised.

No progress has been made on the recommendation because the Commissioner has limited means to influence those who publish university rankings. A Discussion Document was published on this topic to trigger wider debate. Some rankings do include a measure of 'value added' to mitigate the dominant focus on academic selectivity and research performance. There have been attempts elsewhere in the UK to devise new more access-friendly rankings. A recent example is London South Bank University's adaptation of the US Social Mobility Index.

Non-Academic Factors in Admissions

Recommendation 14

The SFC should undertake an independent review of the processes – such as personal statements and interviews – that are used to evaluate non-academic factors in applications, with the aim of assessing whether, and to what extent, they unfairly disadvantage access applicants.

This recommendation has not been achieved in its stated form. It is not clear that this task lies within the remit of the SFC rather than individual universities which are responsible for admitting students. So no formal review has taken place. As well as institutions, professional and other accreditation bodies are also potentially involved. The challenge of setting minimum entry requirements has exposed to wider scrutiny the use of 'non-academic' factors. The suspicion lurking behind this recommendation, that the use of personal statements and interviews, may favour applicants from more socially advantaged backgrounds (for example, from independent or high-performing state schools), although real, may be unjustified. It is just as possible that universities rely too heavily on exam grades in determining entry and too little weight is placed on personal statements (perhaps because they are regarded as over-crafted) and interviews (except in some professional and performance subjects).

Early Years

Recommendation 15

Universities and colleges should increase engagement with our youngest children and their families as part of the provision of a coordinated package of support for those in our most deprived communities in line with Recommendation 4.

Important work has been done in terms of engagement with pupils in the later years of primary education, and some excellent initiatives along the lines of 'children's universities' have been taken. Inevitably this work and these initiatives have been badly disrupted by the Covid-19 emergency, and resources will need to be targeted to restore their momentum.

On the one hand, it can never be too young to start focus on the impact of social disadvantage, rooted in socially deprived communities, on future access to higher education. On the other hand, any interventions at early years and primary level need to be sustained through secondary education, which is clearly expensive. The challenge for universities is to focus their investment in access on those interventions that are most effective, one of the tasks of the Scottish Framework for Fair Access. Addressing social deprivation on a wider scale is the primary responsibility of local authorities, the Government and Parliament.

School Attainment

Recommendation 16

Universities, working with schools, should take greater responsibility for the development of the pool of applicants from disadvantaged backgrounds by delivering academically based programmes to support highly able learners, who are at risk of not fulfilling their academic potential.

Substantial efforts have been made by universities, in partnership with colleges, to increase the pool of qualified applicants from more socially deprived communities. These have taken the form of special courses in high-demand subjects such as medicine (the scenario the Commission probably had in mind when it framed this recommendation), summer schools and other forms of bridging programmes. Once again, these activities have been disrupted by the Covid-19 emergency, and need investment to get back on track. Charities such as the Robertson Trust, the Sutton Trust and others are also active in helping high-potential students from more disadvantaged backgrounds meet the entry standards set by universities. The Universities of Edinburgh and Glasgow have recently launched new partnerships with INTO Scotland not only to focus on boosting the achievement of individuals but also investing in the wider learning environment in deprived communities in their respective cities.

Information, Advice and Guidance

Recommendation 17

SDS and schools should work together to provide a more coordinated, tailored offer of information, advice and guidance to disadvantaged learners at key transition phases throughout their education.

It is not clear what progress has been made towards implementing this recommendation. SDS has continued its work with Education Scotland, local authorities and schools to develop its career education standard, which has led to earlier interventions at the transition from primary to secondary school and S2/S3 when subject choices are made. The SFC has also funded initiatives about improved guidance.

Access to Key Subjects

Recommendation 18

Universities, colleges and local authorities should work together to provide access to a range of Higher and Advanced Higher subjects, which ensures that those from disadvantaged backgrounds or living in rural areas are not restricted in their ability to access higher education by the subject choices available to them.

This recommendation has been partly implemented. A number of Advanced Higher hubs have been established based in universities, or colleges, for example, at Glasgow Caledonian University. These hubs enable pupils to study for Advanced Highers in subjects which their schools cannot offer because only a few pupils want to study them and such provision would not be viable logistically or satisfactory educationally.

Financial Support for Learners

Recommendation 19

The Commissioner for Fair Access should commission research, within three months of appointment, to assess how student finance impacts on the participation of disadvantaged learners in higher education.

Recommendation 20

Disadvantaged learners and their parents, should be provided with clear, accurate information on both the availability of student finance and the conditions for repayment. This should be taken forward by the bodies identified in Recommendation 17 and the Student Awards Agency Scotland.

The first of the recommendations has not been implemented. Before the Commissioner had begun work, the Government itself had established a wider Independent Review of Student Support which reported in June 2018. This seemed a more sensitive way to address the issue of financial support, although the focus of the review was on all students not just disadvantaged learners because the Commissioner had neither the resources nor the authority to promote substantial change. Although the Government did provide some additional funding to increase bursaries for students from low-income families, it had not produced a comprehensive response to all the Independent Review's recommendations, which focused strongly on the need for clear and accurate information – the second recommendation – before the onset of the Covid-19 emergency. That emergency exposed, and exacerbated, student poverty more generally.

One issue raised by the Independent Review, the relationship between the availability of student financial support and eligibility for social security benefits (not helped by the fact that the first is the responsibility of the Scottish Government and the second primarily of the UK Government), remains to be addressed. Students face a particular problem over the summer, particularly at the moment because the availability of part-time jobs has been reduced. This whole subject remains very much work-in-progress.

Supporting Those with Care Experience

Recommendation 21

By 2017, those with a care experience, who meet the access threshold should be entitled to the offer of a place at a Scottish university. Entitlement should also apply to those with a care experience who have had to take a break from higher education and wish to return. Learners should be assessed against minimum entry level in 2017 and 2018 and the access threshold thereafter.

Recommendation 22

The Scottish Government should replace student living costs loans with a non-repayable bursary and provide a more flexible package of student support for learners with a care experience from academic year 2017-18.

Recommendation 23

The Scottish Government should develop an approach to allow those with a care experience to be identified from early years to post-school and on to employment to enable additional support, for example, a marker or a flag. Young people with care experience must be included in the development of how this would be used and shared.

Since 2019 all universities now guarantee offers of a place to care-experienced applicants who meet minimum entry requirements. This will help to address the very low participation of young people with care experience in higher education – only a tenth of the participation rate for all school leavers.

It has not been specified whether this guarantee applies to all potential care experience applicants, regardless of the time gap between leaving care and contemplating applying. Also applications tend to be focused on a limited range of courses with limited capacity and professional requirements. Overall careful monitoring is needed of the impact of this guarantee because applicants have to meet MERs.

In 2018-19 the Government allocated an additional £5 million to increase the care-experienced bursary to £8,100 a year. The previous age limit has also been lifted.


Recommendation 24

The SFC should review the best use of its funds, specifically the Access and Retention Fund, to deliver the implementation of the Commission's recommendations.

Recommendation 25

The SFC should monitor how institution spend from core funding is being used to support access through the Outcome Agreement process.

Recommendation 26

By 2021, the SFC, in consultation with the Scottish Government, should explore options for more targeted funding models to better support the recruitment and retention of greater numbers of access students.


Recommendation 27

The SFC should make more extensive use of their existing regulatory powers, where appropriate, to drive greater progress. The Scottish Government should ensure that it provides the SFC with the necessary mandate to take this action.

Recommendation 28

The Scottish Government should ensure that objectives relating to fair access are embedded in the regulatory frameworks of other agencies/public bodies with a role to play in advancing equal access.

In recommendations 24 to 27 the Commission urged the SFC to use its funding and regulatory powers in a more focused and prescriptive way to support fair access, and in recommendation 28, that the Government should ensure fair access was taken seriously by other agencies and public bodies. The response, from the SFC and the Government (with regard to the SFC; it is not clear the Government has taken sustained action to extend the focus on fair access to other public bodies), has been at two levels.

  • The first has been operational. The SFC has continued to support and refine its support for fair access, through the inclusion of fair access in outcome agreements and earmarked funding and project funding. The emphasis here has been on continuity with incremental, although welcome, change.
  • The second is strategic. Initially Ministers through their guidance to the SFC encouraged it to 'intensify' outcome agreements with institutions, which has been interpreted as a desire to increase accountability (and consequences if agreed targets are not met). Later, the SFC established a review of Scotland's colleges and universities, under the general heading of 'coherence and sustainability'.

This is a complex exercise divided into three phases, only one of which has been completed. So it would be unfair to draw premature conclusions. But it is worth noting that the focus of the review, which presumably reflects the priorities of the Government, has been on global competitiveness and research, relationships with the economy (and economic recovery post-Covid), integration of provision, and avoidance of confusing (and expensive) duplication.

One of the SFC's 10 themes is especially welcome – the development of 'an integrated, connected tertiary education and skills eco-system for learners and employers', with fair access ('better ladders, bridges and pathways') as a sub-theme. It would have been good, and more in the spirit of the Commission's recommendations (and the First Minister's pledge to remove inequitable access by 2030), to have seen fair access given a more prominent, and independent, place in the review, with greater emphasis on social justice.

Better Use of Data to Support Fair Access

Recommendation 29

The Scottish Government should improve mechanisms to track learners and share data to support fair access. Specifically, the Government should:

  • lead the work necessary to develop and implement the use of a unique learner number to be used to track learners' progress from early learning, throughout education and onwards into employment;
  • review data access arrangements to provide a national process for the provision of information to practitioners and policy makers working on fair access. This review should consider access to and sharing of data held by local authorities, schools, UCAS and SAAS.

These recommendations have yet to be implemented. A unique learner number has not yet been implemented, despite the work of the Access Data Group which was established in March 2018 and met four times. Instead the work of the Group focused on access measures (Recommendation 31). Data sharing on this scale, and on a consistent basis, is difficult to achieve. It poses not only logistical and reliability but also data protection and privacy issues. Also, although some young people are consistently disadvantaged at every stage, from early years through to employment, for others it may be an intermittent experience. So multiple and shifting populations are involved. Despite these difficulties this remains a key recommendation, progress towards which appears to be another victim of the Covid-19 emergency.

Recommendation 30

The Scottish Funding Council and the Scottish Government should enhance the analyses and publication of data on fair access.

Since 2017 the SFC has published an annual Report on Widening Access (which this year is published at the same time of this report). In earlier years the report has been published earlier in the spring. This year it has been delayed by the Covid-19 emergency. Earlier is better, because HESA publishes in January UK-wide performance indicators for individual institutions which cover data on the recruitment of students from disadvantaged communities, but by POLAR (ie areas of low HE participation) not MD (areas of multiple deprivation). It would be helpful if the ROWA could be published at the same time, or soon after, the HESA statistics.

Measures to Identify Access Learners

Recommendation 31

The Scottish Government and the Scottish Funding Council, working with key stakeholders, should develop a consistent and robust set of measures to identify access students by 2018.

Fair access targets continue to be expressed solely in terms of the SIMD areas from which applicants and entrants come. There is a general agreement that use of this sole metric involves false positives, ie better off applicants/entrants who live in areas of generally poorer communities, who therefore count towards meeting targets, and, more seriously, do not include poorer applicants/entrants from generally more advantaged communities, which is a particular issue in more sparsely populated rural and remote areas.

The Access Data Group considered a range of individual measures to supplement SIMD, and recommended the use of take-up of Free School Meals (at any time during secondary schooling). This has yet to be implemented. Although the Access Delivery Group when it received the report of the Access Data Group was broadly supportive, the Government has yet to take a decision. It also remains unclear whether the targets should be recalculated to include two measures, SIMD and FSMs, or whether take-up of FSMs should simply be used alongside the primary measures, SIMD. There are dangers in recalculating targets because it would make it more difficult to measure progress in a consistent way. Also it would be necessary to re-write, or re-express, the First Minister's original pledge that by 2030 young people from the 20 per cent most deprived areas in Scotland should make up 20 per cent of university entrants, which is the founding text of the current focus on fair access.


Recommendation 32

The Scottish Government and the Scottish Funding Council should implement the following targets to drive forward the delivery of equal access in Scotland:

To realise the First Minister's ambition of equality of access to higher education in Scotland:

  • By 2030, students from the 20% most deprived backgrounds should represent 20% of entrants to higher education. Equality of access should be seen in both the college sector and the university sector.
  • To drive progress toward this goal:
  • By 2021, students from the 20% most deprived backgrounds should represent at least 16% of full-time first-degree entrants to Scottish HEIs as a whole.
  • By 2021, students from the 20% most deprived backgrounds should represent at least 10% of full-time first-degree entrants to every individual Scottish university.
  • By 2026, students from the 20% most deprived backgrounds should represent at least 18% of full-time first-degree entrants to Scottish universities as a whole.
  • In 2022, the target of 10% for individual Scottish universities should be reviewed and a higher-level target should be considered for the subsequent years.

This recommendation has been implemented. The targets recommended by the Commission were accepted by the Government. They form the basis of the national efforts, and efforts of individual institutions, to achieve fair access. The 2021 national target has been met. But no consideration has yet been given to whether the 10 per cent target for individual universities should be increased.

The successful progress that has been made so far may have created two risks: of overall complacency, which may be misplaced in the context of any setback resulting from the Covid-19 emergency; and disengagement by institutions which have met or exceeded the targets, although for most of these institutions widening access is a key part of their missions.

Agenda for The Future

Recommendation 33

The Commissioner for Fair Access should:

  • consider what further work is required to support equal access for other groups of learners and within specific degree subjects;
  • consider what further work is required to support equal outcomes after study for those from disadvantaged backgrounds or with a care experience.

This recommendation has been partly implemented. The Commissioner has identified other forms of disadvantage such as age, gender, disability, ethnicity and care experience alongside socio-economic deprivation as measured by SIMD, and also examined in greater detail challenges to fair access in three contrasting professions, medicine, law and the creative industries with recommendations to the Government, institutions and professional bodies.

Final Recommendation

Recommendation 34

The Scottish Government should report on progress against the recommendations it accepts from this report, 12 months after issuing its response. Thereafter, progress towards equal access should be reported on annually by the Commissioner for Fair Access.

This recommendation has been partly implemented. As has already been indicated, the Government in its May 2017 progress report identified a number of 'foundational' recommendations which it regarded as especially important. Progress on these and other recommendations was regularly reported on to meetings of the Access Delivery Group until the onset of the Covid-19 emergency. In his Annual Reports the Commissioner has not offered a comprehensive review of progress on all recommendations, instead adopting a selective approach and focusing on progress towards meeting the access targets.

Overall assessment

Many of the recommendations of the COWA final report have been implemented, although not always in the exact form envisaged by the Commission. This confirms the Commission's status as a key intervention in the process of achieving fair access in higher education. Without that intervention the clear sense of direction that has characterised policy in this area in Scotland could not have been achieved.

This is particularly the case in relation to the 'foundational' recommendations identified by the Government as essential to implement in order to achieve fair access. Aside from the appointment of a Commissioner for Fair Access, three 'foundational' recommendations – or groups of recommendations – have been unquestionably implemented: (i) on the adoption of targets to drive fair access; (ii) on the introduction of access thresholds for all degree courses and greater transparency of these thresholds [minimum entry requirements] and other contextual admissions policies; and (iii) guaranteed offers of a place, and a bursary, for all care-experienced applicants who meet these minimum entry requirements. The other 'foundational' recommendation, the establishment of a Framework for Fair Access, has also been implemented but not yet on a secure and sustainable basis. This will be discussed in the final section of this Annual Report.

Of course, there is continuing debate on two important questions with regard to these 'foundational' recommendations; first, the extent to which other metrics, notably FSMs, should be used alongside SIMD in defining targets; and, secondly, whether all minimum entry requirements have been set at a sufficiently ambitious level. In retrospect it also seems unfortunate that progress towards smoother articulation between HNs and degrees, and more generally the development of more flexible pathways, was not included as a 'foundational' recommendation.

The COWA report included a list of unfinished business, important areas the Commission had not had time to examine in detail.

1. Outcomes of disadvantaged learners following graduation, including access to postgraduate study

2. Additional barriers faced by people with protected characteristics

3. Additional barriers for carers, former offenders and young people leaving the armed forces

4. Access to high-demand degree subjects (e.g. medicine)

5. Access to higher education for those from rural areas

6. Access to part-time study

All of these areas have received some attention since the COWA report, although with different degrees of urgency. In the case of graduate and employment outcomes a lot of emphasis has been placed on 'success' as well as 'access' – by Ministers and also University Principals. A lot of data has also been collected on continuation and completion rates and degree outcomes among students from more socially deprived backgrounds, much of it encouraging. The particular needs of more disadvantaged students living in rural and remote areas have also received a lot of political, if not yet policy, attention, although mainly in the context of the debate about the use of SIMD as the only metric for assessing progress towards meeting access targets. Successful programmes have also been developed with regard to high-demand subjects such as medicine.

More limited attention has been given to the rest of the list. As Commissioner I have published discussion documents on access to postgraduate study and those with protected characteristics, but without any follow-through in terms of policy. Of particular concern is the lack of attention on part-time study, although it plays a key role in providing access to higher education for students from more deprived communities. Fair access in Scotland is still predominantly seen in terms of 'first chances' not 'second chances'.

Two final points are worth emphasising.

  • First, many of the COWA recommendations were addressed to the Government and the SFC. Some had a top-down tone and rather dirigiste feel. As it has turned out, much of the activity has been bottom-up; or, at any rate, taken by the institutions themselves. In many cases the universities have taken the initiative, collectively and individually. That has been both a strength and weakness: a strength because institutional autonomy has been respected and universities have developed a strong sense of ownership of the access agenda; a weakness because the rate of future progress will be influenced by what is acceptable to institutions, and therefore to mainstream academic opinion (which is not always especially radical or adventurous on this subject), and also perhaps because the SFC has not been able to develop a sufficiently strong strategic as opposed to detailed operational stake in the process that is distinct from those of the Government and the institutions (acting through their sectoral bodies). If progress towards fair access is set back by the multiple effects of the Covid-19 emergency, these weaknesses could become more serious.
  • Secondly, there has been proliferation of advisory, delivery and programme groups usually known by the acronyms of their titles. Even the well-informed may struggle to understand how these groups relate. There is a need to make the policy architecture of access more transparent, especially to key stakeholders outside higher education such as schools and employers, and perhaps simpler. This is not wholly, or even mainly, the fault of the Commission for Widening Access but rather a result of the implementation process that has followed its report. The need to address this opacity of the policy and implementation architecture is another aspect of the wider need to make access generally more accessible, by explaining or replacing terms such as 'contextual admissions', 'access thresholds' and 'articulation'. Just as the experience of higher education itself needs to be demystified for potential applicants without family or peer knowledge of what is involved, so the language of access needs to be demystified if it is to maintain or increase support for this agenda across the range of academic and institutional opinion and, more widely, political and public opinion.


Email: karen.frew@gov.scot

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