Your views
7. Please share your response below.
Please share your response below.
(Required)
Despite consultation between 2021 and 2023, no mention of fees was made. In October 2023 the board confirmed its principle policy, but did not adequately consult on fees and how the shift in funding accreditations should be met by institutions and providers. The Boards decision was made and implemented without consultation and justification of them, this is reflected in the collective voice and reaction from them via SCOSA.
In respect to the introduction of the new fee structure(s), again comes the lack of consultation, but also it comes at a time when ARB is wanting to remove Part 1 prescription. Prescription end dates were extended but with no reference to a new fee structure, how can it be that you extend a prescription period then change the terms and conditions for it afterwards? Within the three fees outlined, no consideration is given to the size of the courses themselves, why has no tiering of the fee structure been considered here to support different sized schools?
The timing of the fee introduction feels like it should be introduced once the transition to the new competencies has taken place and the Part 1 prescriptions have ceased, this would make more sense. Soon students will start courses which have been advertised as 'ARB Part 1 prescribed', yet will not graduate from them. What will institutions and providers actually be paying for if graduates will receive no benefit from it?
The 'law' is quoted in respect that "fees must not exceed the reasonable costs of providing the service", who determines what is "reasonable" here because if anything the actions and steps taken appear unreasonable. How have these fees been arrived at?
The board 'decided' to introduce fees, it set out dates, it set out when payment was due (September 2024) but has any provider signed up to this? 'Accreditation Rules' have been introduced with no true consultation on a fundamental part now in question.
ARB's actions from October 2023 and its introduction of fees in such a poor way undermines the 2-year consultation process, it contributes to a loss of faith. Casing point is this survey being introduced with "Whilst we are not able to change anything that is set by legislation, we welcome feedback on the following", this suggests nothing is going to change despite the lack of consultation on fees themselves, it raises the question is ARB really interested in the "disproportionate impact" they will have on the stakeholders impacted by ARB's actions? Which can only be corrected by reviewing how it introduces fees and how they should be structured.
There is a better solution to be offered (hopefully!).
In respect to the introduction of the new fee structure(s), again comes the lack of consultation, but also it comes at a time when ARB is wanting to remove Part 1 prescription. Prescription end dates were extended but with no reference to a new fee structure, how can it be that you extend a prescription period then change the terms and conditions for it afterwards? Within the three fees outlined, no consideration is given to the size of the courses themselves, why has no tiering of the fee structure been considered here to support different sized schools?
The timing of the fee introduction feels like it should be introduced once the transition to the new competencies has taken place and the Part 1 prescriptions have ceased, this would make more sense. Soon students will start courses which have been advertised as 'ARB Part 1 prescribed', yet will not graduate from them. What will institutions and providers actually be paying for if graduates will receive no benefit from it?
The 'law' is quoted in respect that "fees must not exceed the reasonable costs of providing the service", who determines what is "reasonable" here because if anything the actions and steps taken appear unreasonable. How have these fees been arrived at?
The board 'decided' to introduce fees, it set out dates, it set out when payment was due (September 2024) but has any provider signed up to this? 'Accreditation Rules' have been introduced with no true consultation on a fundamental part now in question.
ARB's actions from October 2023 and its introduction of fees in such a poor way undermines the 2-year consultation process, it contributes to a loss of faith. Casing point is this survey being introduced with "Whilst we are not able to change anything that is set by legislation, we welcome feedback on the following", this suggests nothing is going to change despite the lack of consultation on fees themselves, it raises the question is ARB really interested in the "disproportionate impact" they will have on the stakeholders impacted by ARB's actions? Which can only be corrected by reviewing how it introduces fees and how they should be structured.
There is a better solution to be offered (hopefully!).