What is the Access and Participation Plan Student Submission?
Since the 2019/2020 academic year, it has been a requirement for most higher education providers in England to have an Access and Participation Plan approved by the Office for Students (OfS), the regulator for higher education on England. These plans outline how universities and colleges aim to improve equality of opportunity for UK undergraduate students in terms of access to higher education, continuation from the first year of study to the second, attainment on degree courses, and progression to further study or a graduate level career.
This year, universities and colleges across England, including UCL, have been preparing new APPs that will be in effect from the 2025/2026. In these plans, universities and colleges hope to identify institutional gaps or risks for opportunity between various groups of students, interventions to address these gaps, and evaluation frameworks to ensure that these interventions are fit for purpose.
The OfS is keen for students to be part of the APP process and expects universities to engage students in the development of their plan. Students are also encouraged to submit their own commentary, usually led by their Students’ Unions or other representative bodies, on the plan and its suitability. Students are invited to comment on each aspect of the plan. They are also given the opportunity to comment on how they were involved in the development of the plan, how they will hold their university to account, and how they anticipate the university will seek to involve them in the delivery and evaluation of the plan.
Our Submission and Why it Matters
These student submissions are an important mechanism through which students can express their views concerning the university’s approach to access and participation and how far this approach is truly meeting the needs of current and prospective students.
As the representative body for UCL students, Students’ Union UCL, led by our Education Officer, Shaban Chaudhary, took responsibility for the coordination of the student submission. In doing so, we reflected on UCL’s APP in the context of our officers’ experiences within the UCL governance structure, especially as related to the development and approval of the APP, sector research on the cost of living, our own evidence taken from our annual Student Priorities for Wellbeing Report and Student Priorities for Education Report, and finally student focus groups.
By and large, we were satisfied that UCL’s APP identified appropriate risks to equality of opportunity and proposed suitable interventions to address these. UCL successfully identified some important risks to equality of opportunity, such as disparities in access and attainment between socio-economic groups and differential outcomes between students from different ethnic background—both of which were echoed in our student focus groups. The plan demonstrated how AccessUCL and UCL’s work in and with schools has successfully contributed to increasing the proportion of students from underrepresented socio-economic groups entering UCL. It also outlined how staff training, resources, and increasingly robust student feedback mechanisms would seek to address issues of differential attainment.
However, while we were persuaded by UCL’s plan, we had several areas of concern which are summarised below:
- Area-based measures
- UCL uses area-based measures, such as the Indices of Multiple Deprivation (IMD), in the setting of access targets related to socio-economic disparities. IMD and other area-based measures assess the relative disadvantage of a geographical area, usually a grouping of postcodes. These types of measures are notoriously difficult to apply in London where there are greater disparities in wealth and relative advantage within postcodes. As UCL is a local recruiter, with over half of its UK undergraduate cohort being Londoners, there is a risk that this use of area-based measures could result in certain groups in London who are underrepresented at UCL being overlooked.
- Mature students
- A further area for concern was UCL’s assertion that the access gap between ‘mature’ students (i.e students aged over 21 at the start of their undergraduate degree) and ‘young’ students (i.e. those aged 21 or under) was simply caused by its full-time teaching provision and that a change to this model would be disproportionate. We found this to be unnuanced, overlooking pedagogical or pastoral issues related to information and guidance, knowledge and prior skills, and perceptions of higher education held by these students. These same factors may be impacting the continuation and attainment gap between mature students and younger UCL undergraduates.
- Cost of living
- Our most significant area of concern was the absence of an adequate consideration of the impact of the cost of living crisis on access and participation at UCL which has implications for many of the gaps and risk identified in UCL’s APP. For example, we found it surprising that financial pressures were not cited as a potential factor effecting socioeconomic disparities in accessing UCL. The cost of moving to, living in, and commuting around London were pressing issues arising from our focus groups. As the recent Russell Group Students’ Unions’ ‘Cost of Living Report’ (2023) demonstrated, students are taking on ever-increasing hours of paid work in order to make ends meet, opting to continue to live with family to cut costs, or considering leaving higher education altogether. This suggests that it is not only mature students who could benefit from a change to UCL’s traditional model. Between commuting and work commitments, even full-time undergraduate students would benefit greatly from a more flexible teaching provision.
- This lack of attention to the cost of living is most obvious in UCL’s bursary scheme which offers insufficient support to a narrow range of students. UCL offers between £1000 and £3000 to students from households with an annual income of less than £42,875. Given that, as demonstrated by a recent HEPI report, students in London living in private rental accommodation would require £21,774 per year to support a basic acceptable standard of living, the support offered by UCL would leave a significant shortfall between the full student maintenance loan and a basic living income. Without additional support, whether from the university or family who themselves may be struggling, students would need to work nearly 19 hours a week at the minimum wage for 18- to 20-year-olds to meet this minimum level of income.
Student engagement and next steps
While we were mostly satisfied that UCL engaged the student body in the development of their APP, we still believe that more can, and should, be done to ensure that the student experience is reflected in UCL’s approach to access and participation. This includes involving students in not only the planning stages, but also the delivery and evaluation of the APP. As the representative channel between UCL students and university, Students’ Union UCL is keen to continue to work with UCL on their access and participation work.
Students’ Union UCL’s APP student submission was submitted to the OfS on Friday 31st May . You can read our submission in full below.