Slicing a loaf of bread with a hammer: why the minimum entry consultation in the Autumn must not disadvantage disabled students. 

This blog was kindly authored by Dr  Meredith Wilkinson, Senior Lecturer in Psychology  and Chair of the Disabled Women in Academia Network De Montfort University, and Professor Deborah Johnston, Vice Chancellor, University of Bedfordshire, and Universities Disability and Access Ambassador.

It has to be assumed that the Department for Education (DfE) toolbox is rather small.  Here we are, debating English GCSE (a level 2 qualification) as a minimum entry requirement for access to the student loan book, when it was only in 2022 that the last discussion stalled in the face of concerns about potential regressive impacts on disadvantaged applicants. Strangely, the conversation has been resurrected just as we have a new government with an ambitious agenda on inclusive educational pathways.

The minimum entry consultation announced by DfE has two background drivers: one is the IFS data on the return to degree-level study, which is entirely silent about English as an entry requirement; and the other is the NAO data on fraud, which suggests that fraudulent franchise providers were enrolling students with a poor grasp of the English language. This blog argues that, in a clumsy attempt to deal with franchise fraud, the DfE has unintentionally suggested a route that would have serious impacts on many disabled students, particularly those from poorer households. Instead, we suggest that DfE works directly with OfS to find better routes to penalise fraudulent franchise providers. 

The context for this discussion is the transformative impact of higher education for disabled people. Whilst there is an employment gap of 3.4 per cent between disabled and non-disabled graduates, this is much smaller than the gap of 29.7 per cent for disabled and non-disabled people in the general population. It is crucial that the consultation in the Autumn does not result in a barrier for disabled individuals with the required skills to undertake a degree to access higher education.   

This blog starts from the position that entry criteria are important, but that, aside from a handful of franchise providers, the sector does this assessment well and is regulated on this through student outcomes. It is critical that students coming to university possess the requisite skills to complete their course. The degree the student wishes to study also needs to be borne in mind.  As Diana Beech argues:

 It would be difficult to justify excluding a gifted musician, designer or performer from higher education simply because they fell short of an arbitrary requirement in an area unrelated to their talents. 

So it is already the case that Professional, Statutory and Regulatory Bodies  (PSRBs) ask for a pass in GCSE-level English for some degrees, such as nursing degrees, and not for others, as in many branches of Engineering. Further, universities look carefully at how applicants can meet entry criteria through alternative pathways.

There is no evidence that an additional GCSE English requirement is needed and we argue that such a requirement would be likely to disadvantage many disabled students. There are two elements to this.

The intrinsic impact of disability and poor access to support.

For example, up to 80 per cent of students with dyslexia leave school without receiving a diagnosis or the right support in place. Further, students may be ‘labelled’ for their behaviour as disruptive or distracted, something which can have significant impacts on their educational journey. The British Dyslexia Association (BDA) found only 4 in 10 students with a Specific Learning Difficulty (SpLD), a category which includes dyslexia, attain a GCSE in English and Maths compared with about 7 in 10 with no identified learning difference.

There is an important class dimension to this that echoes concerns raised by others about the lack of fairness in the minimum entry proposals. School support for dyslexic learners is heavily affected by having a formal diagnosis. However, in other results, the BDA found that of young dyslexic people with a household income above £100,000, 90 per cent had a formal dyslexia diagnosis, compared to only 43 per cent in households earning less than £30,000. With household income having such an impact on having a formal diagnosis, the issue of school performance becomes an issue of disability and poverty. With no universally accessible assessment pathway, one parent told BDA researchers that without being able to afford a private assessment, their child would not have received a diagnosis or the support associated with it.

The same general relationship between GCSE success, disability and poverty is relevant for other conditions such as dyspraxia, ADHD, autism and speech, language and communication needs. Research from Durham University and Oxford has found that identification of specific learning difficulties is not evenly distributed across schools. The study analysed more than 540,000 Year 6 pupils across approximately 14,800 schools and among other things, found that children in higher-achieving schools were more likely to be identified. 

That creates a rather uncomfortable policy proposition: a student may be more likely to be prevented from accessing university finance precisely because they were a disabled child whose family could not afford to have their disability identified, or they were in a poorly-resourced school that did not identify and support their needs. The policy risks treating the GCSE English outcome as evidence of underlying capability, when the outcome may partly reflect whether parents could afford private diagnosis and whether the education system identified and accommodated the disability.

What could DfE do if they want to steam-roller ahead, given the evidence about disadvantage for poorer, disabled students? 

DfE will struggle to suggest that disabled applicants can make use of other routes to university, as the two main alternatives will be out of reach.  First, many  Access to HE courses already require a Level 2 pass in English.  Second, beginning on a foundation course requires access to the student loan book that DfE wants to deny to those without a GCSE English pass.

So can DfE Students solve the underlying problem with the acquisition of Level 2 English? They could give disabled applicants the opportunity to retake GCSE English during their degree, with the argument that now, with diagnosis and the right support, they will have a better chance of success.  However, GCSE timetables are quite rigid and would involve applicants in a long pre-sessional period.  DfE could instead ask for a more flexible Level 2 qualification, Level 2 Functional English, widely provided through Further Education colleges and provide a more flexible way to achieve Level 2 English than a GCSE.  However, Functional English courses can still take anywhere between 4 and 12 weeks to complete.  Again, DfE would need to consider how these additional study requirements interact with the inflexibility of course start dates. Otherwise, some disabled applicants will find that they are delayed by an entire academic year.

What could the DfE do instead?  They could even develop a test of English language proficiency, both written and spoken, that could be utilised to create a minimum-level threshold that would also have more applicability to everyday life. 

This article argues that any GCSE or Level 2 English requirement is a clumsy move by the DfE.  Where a pass at Level 2 in English is needed for degree success, it is already required.  Instead, the DfE is on alert because of the inability of the regulator to clamp down on a handful of fraudulent franchises who have recruited students without adequate English skills. In reaching for a minimum English GCSE to solve the problem, poor and disabled students will be disadvantaged in a way that undermines the ‘keeping Britain working’ ethos. Instead, DfE and OfS should work to regulate franchise provision in the sector more effectively.