23 Apr 2019
MillionPlus agree with the proposal for a flat fee from institutions to cover what the QAA refer to as infrastructure costs, but reject the proposal for banded fees as it is difficult see the justification for charging institutions more for central QAA costs purely because they (the institution) has a larger student population. Where the QAA is charging for work related specifically to the institution (e.g., the assessment fee for registration or DAPs ) this fee already takes into account the duration and complexity of the activity (which may or may not be based on student population).
Notwithstanding some of the points made in the proposal regarding the legal situation of fees (from HERA 2017), the reality is that, internationally, potential applicants will primarily see the UK as one system. Therefore, international work by QAA benefits all providers, whether they are domiciled in England, Scotland, Wales or Northern Ireland. This would suggest that it is more sensible to include the cost of this in the standard subscription providers pay to the QAA – in this case the infrastructure fee. In addition, while we do not want to necessarily discourage new providers who can offer something of quality to students, they need to meet a high bar to enter – and the cost of that should be borne by them individually, not by the rest of the sector.