Ellen Graves, GuildHE Policy Officer, scrutinises the motive behind the DfE Non Medical Help Call for Evidence in a thought-provoking blog.

The Department for Education’s Call for Evidence on improving non-medical help (NMH) for disabled students asks the sector what works in the current system, and how it can be improved. Crucially, the review, almost posed as a consultation rather than a call for evidence, also asks whether we should move from the current individual funding entitlement model to one where responsibility for NMH falls to institutions. 

Our recent interviews with heads of student and disability services revealed a clear message: there’s room for improvement in Non-Medical Help (NMH) provision. Reducing access barriers, tackling supplier shortages, and fostering better communication between DSA, suppliers, and institutions are all crucial steps. 

However, the framing of this call for evidence led us to question the motivations and rationale of the review and it could be considered premature in trying to evaluate the impact of very recent DSA reforms. Additionally, the way the consultation questions are framed suggests that a more inclusive approach and a shift towards the social model of disability by HE providers could potentially eliminate the need for individual NMH support through DSA.

Institutions are already taking steps to implement inclusive measures and are emphatic in stating that not all additional learning needs can be mitigated by inclusive design. Furthermore, given that bodies crucial to DSA support such as SLC have yet to themselves adopt the social model of disability, and the lack of transparency over how or even if the change in model would be adequately funded, the DfE’s motivations and rationale for the call for evidence becomes hazier. 

It’s not either/or 

The most contentious question in the call for evidence is  “Do you consider it more important for a student to have an individual entitlement for more specialist NMH support or for a HEP to have overall responsibility for the whole of a student’s NMH support?”, with the rationale again that an institution-responsibility model would better enable NMH to be embedded into inclusive design. 

Yet the premise of this question is flawed. The two types of provision proposed should not be and are not mutually exclusive, nor can one be more important than the other, as the question appears to infer. Posing these two types of support against one another creates a false dichotomy. It suggests that individual entitlement would not be available within the higher education institution-responsibility model. DfE’s rationale for the review also appears to suggest that individual entitlement is a blocker or barrier to universal/inclusive design. 

Yes, inclusive design is incredibly valuable in improving accessibility for all and shifting the burden for the mitigation of needs away from students. However, inclusive design and technology cannot and should not be a replacement for individual, tailored and human support for certain students. Both are needed. The level of support required varies across and within disability types, as well as the student’s preferences, their historic experiences of support, and the type of subject they are studying. 

GuildHE members’ learning spaces are often technical or applied and specialist. Tailored NMH provision and a bespoke needs assessment that reflects a genuine understanding of these different pedagogies is vital to addressing individual students’ needs. Alternative assessment as an inclusive practice is also not always possible for courses with PSRB standards, making study skills support vital for certain students.  

Shifting the burden?

The hazy rationale and ill-thought through questions call into question the actual motive of the review. In a climate of budgetary cuts, where the shift in service model to Study Tech and Capita was partially motivated by cost-cutting, many of our members have expressed concerns that the proposed change is in actuality a money saving exercise. An exercise that, as with the removal of Bands 1 and 2 from DSA, will continue the stripping back of DSA-provided support and shift the financial and administrative burden of NMH support to institutions and their support services. 

This shift in burden is of particular concern for our members and for specialist institutions, who often have a higher proportion of students in receipt of DSA support. In 2021/22, GuildHE members had an average of 24% of students with a declared disability, compared with 15.7% across all HE students and in some specialist creative institutions, more than 30% of their student population have a declared disability.

Making sense of it all 

In our response to the call for evidence, GuildHE proposed a way forward to help make sense of NMH, individual support and inclusive design, and highlight that not one size fits all institutions, disciplines and students. 

A national framework, developed with the sector, could use the social model of disability to map out where inclusive design can break down barriers and bring value, the circumstances in which students may need individual, tailored support (whether that be the student’s individual need or disability, or the course studied), and what that all looks like. This solution would enable a joined up approach between individual, contextualised support and inclusivity embedded into pedagogy and highlight that pedagogies at different HEIs and in different courses can translate into different student needs. It could also encourage buy-in across the sector and DSA by emphasising the importance of both types of support, so crucial in ensuring that students with disabilities succeed in their studies and have a positive higher education experience.