Introduction

1. This publication provides guidance to the internal auditors of higher education institutions (HEIs) and further education institutions (FEIs) funded by Medr for higher education provision referred to throughout as higher education providers (HEPs) to use for their annual internal audit of the internal controls relating to the systems and processes in place to produce higher education (HE) data returns, and requests a copy of this internal audit report for each HEP.  Both HEFCW and Medr are referenced throughout this publication depending on historic or current data and processes.

2. Previously, external audits were commissioned by HEFCW so that HEPs were externally audited at least once every four years. 2021/22 was the last year of the contract HEFCW had with external auditors to do this and so in Medr we are continuing with the interim process used last year in place of external audits until the audit process is reviewed.

3. For 2025 the process will involve members of the Medr Statistics team meeting with data contacts at each HEP, to cover items such as previous audit findings, Data Futures implementation and review, and data quality. As part of this interim process, Medr will continue to rely on the annual assurance provided to HEPs and their Audit Committees by their internal auditors about the systems and processes used to produce data returns. Relying on the internal audits will maintain an adequate level of annual assurance in respect of HEPs’ data returns.

4. The internal audit will provide an opinion as to the adequacy and effectiveness of the controls in place to manage the risks relating to the accuracy of data submitted by the HEP to the Higher Education Statistics Agency (HESA), Medr and Welsh Government (WG), including data used in calculations for the following funding streams:

• Teaching funding (currently comprising per capita and premium funding and part-time (PT) undergraduate (UG) credit-based funding);
• Research funding comprising Quality research (QR) funding and Postgraduate research (PGR) training funding;
• Research Wales Innovation Funding (RWIF);
• Medr’s part-time undergraduate fee waiver scheme;
• Well-being and mental health funding;
• Race access and success funding;
• Targeted employability support funding;
• Wales Research Environment and Culture (WREC) funding;
• Capital funding.

and the data used to monitor the following funding streams:

• Medr’s part-time undergraduate fee waiver scheme;
• PGT Master’s bursaries allocations;
• Medr funded Degree Apprenticeship scheme allocations.

5. The internal audit should also provide assurance over the controls in place to ensure the accuracy of data used in the monitoring of performance, including key performance indicators such as the National Measures, and if applicable, data included by HEPs as part of the fee and access plan reporting requirements.

6. The Data Futures programme was implemented for the 2022/23 HESA student record. There were difficulties with the return caused by delays to the functionality of the HESA Data Platform, late software updates, late supply of data quality rules by Jisc and other issues in its implementation year.  In light of this, for the 2024 audit scope we didn’t recommend that auditors examine the implementation of the new record for 2022/23 in depth, or the systems and process relating to the 2022/23 return, but rather provide opinions on the controls in place to manage risks relating to the record going forward including plans to review and/or improve processes, documentation and data quality moving into the 2023/24 return. Difficulties were also experienced in returning the 2023/24 student record and this may mean that providers have not been able to fully implement new processes and procedures for their systems and auditors should take these difficulties into account when setting out their programmes of work for 2025. We would expect auditors to include in the scope any updates applied to systems and processes, and to risk registers, after review of both the 2022/23 and 2023/24 student data returns.

7. This document provides guidance to the internal auditors about the nature of the controls that their audit should address, to assess whether the systems and processes are adequate to provide accurate data returns and data to use in funding and monitoring and also to ensure that internal audits taking place across the sector are carried out on a consistent basis.

8. If the internal audit report’s overall conclusion, or the conclusions relating to the adequacy of the design of the methods of control and the application of those controls, provides a negative opinion (e.g. limited or no assurance, unsatisfactory or inadequate controls) and/or the report includes a significant number of recommendations, Medr should be notified as soon as the opinion has been agreed. Medr will then conduct their own assessment of the issue and/or commission their own external audit as appropriate. This external audit would consider the accuracy of data for the current period and also consider the findings of the internal auditor and aim to assess the extent of potential errors in the data returns and data used for funding and monitoring for prior periods up to the last external audit. The findings of this external audit may result in adjustments to funding and further action may be taken if HEPs are found to be not compliant with their fee and access plans, the supply-side code of practice for data collections or the financial management code.

Scope of the Audit

9. The way in which internal audit work and controls testing is carried out at each HEP will depend on the systems and controls in place and how information is shared within the HEP. However, it is expected that the internal audit work will cover the elements highlighted in this document. Where previous internal audit work has found that the systems and controls in place are satisfactory, it may be considered appropriate by the HEP’s Audit Committee for subsequent audits to only cover areas of risk. In particular, due to the increased risks associated with the implementation of the HESA Data Futures programme in 2022/23 and into 2023/24 collection, we would expect to see this area of work included in the scope, (See also paragraph 62).

10. Auditors should ascertain the processes by which data returns and monitoring information are compiled and document them to the extent necessary to enable an evaluation to be made of the adequacy of the existing controls used by the HEP to ensure that they produce accurate data returns and appropriately compile monitoring data. Examples of the controls that the audit would normally be expected to assess are set out for all the current funding streams, data returns and other areas of audit in the sections below. Many of the controls are common to the data returns for all areas of audit. However, not all of the areas of audit apply to all HEPs, and auditors should refer to the relevant paragraphs.

11. Auditors should note that there are some areas where HEPs may have to return estimates, where information is not known at the time of return or information is not available in the required form. Estimates can be made using methods suggested by HEFCW/Medr in its guidance, or if appropriate, HEPs can use their own methods. Where estimates have been made, auditors should review the methods used to calculate them, confirm that they are properly documented, reasonable, consistently applied and tested for reliability.

12. If a HEP is in the process of merging or has recently merged with one or more other HEPs, the auditor should ascertain if procedures have been put in place to integrate their data systems or otherwise ensure that returns for the whole merged HEP can be made.

13. In planning the audit, the Auditor should consider the findings and conclusions of the latest external and/or internal audit reports relating to systems and data returns for the HEP and any follow up reports and correspondence with management to assess the extent of implementation of the reports’ recommendations. It is expected that the audit reports will make reference to and comment upon the extent that recommendations made by auditors in the previous internal or external audit reports have been effectively implemented.

14. Additionally any data issues or errors notified either directly to Medr by the provider, or identified and communicated by HEFCW/Medr, should be referenced in the report together with any action taken to ensure that data systems and processes have been amended where appropriate to mitigate against any such errors in future. As explained in paragraph 6, there were difficulties with the implementation of the Data Futures programme. This led to multiple errors being flagged and tolerated in the HESA student record issue management system (IMS) in both 2022/23 and 2023/24. We are not expecting auditors to review these errors, but would recommend any review for the HESA student record for the 2023/24 return focus instead on providers’ plans to review these errors and any action they might take to improve systems and processes moving into future HESA student record returns.

15. It is recommended that internal audit staff with some experience of the HE sector and associated data returns are involved in the visits to HEPs undertaken as part of the review and that auditors are sufficiently briefed on the guidance contained within this publication prior to carrying out the audit. In addition, auditors should make themselves aware of the UK-wide issues experienced with the implementation of Data Futures in 2022/23 and the issues experienced for the 2023/24 return. Advice and clarification relating to the guidance in this publication can be obtained from Medr via [email protected], and Medr staff are available to meet with internal audit staff if required.

16. All HEFCW/Medr publications described below are available via the relevant links in this publication or can be obtained from Medr directly via [email protected].

Funding Methodology and Data Requirements

17. HEFCW circular W24/13HE HEFCW’s Funding Allocations 2024/25 describes the overall funding distribution for academic year 2024/25 including:

• PGR and QR funding (pages 6&7)
• RWIF (page 7)
• Teaching funding (pages 8 to 11)

W24/13HE also includes funding which is further described in the following publications:

• Well-being and health strategy funding (Medr/2024/07)
• Part-time undergraduate fee waiver scheme (W24/15HE)
• Race equality in higher education allocations (Medr/2024/03)
• Targeted employability support for students (W23/15HE)

18. HEFCW circular W23/27HE Higher Education Data Requirements 2023/24 informs HE providers of the 2022/23 data used to calculate funding allocations and used for monitoring purposes, as well as student eligibility criteria for:

• Per capita funding (Annex A para 18)
• Access and retention premium (Annex A para 20)
• Disability premium (Annex A para 34)
• Welsh medium premium (Annex A para 36)
• Expensive subjects premium (Annex A para 41)
• Higher cost subjects premium (Annex A para 46)
• Part-time undergraduate fee waiver scheme (W24/15HE)
• Race equality in higher education allocations (Medr/2024/03)
• Targeted employability support for students (W23/15HE)

19. Medr publication Medr/2024/01 Higher Education Data Requirements 2024/25 informs HE providers of the data used to calculate funding allocations and used for monitoring purposes using 2023/24 HESA student record data.

20. Due to the implementation of HESA Data Futures, auditors should note the caveats included for 2022/23 and 2023/24 data, given the new nature of the data return, in paragraphs 3 and 4 of Medr/2024/01, and our expectations about audit of the systems and processes for the 2023/24 HESA student data return described in paragraphs 6 and 14 of this publication.

21. Annex A of this publication contains an outline of the methodology used to calculate the formula driven elements of credit based funding for teaching, RWIF, PGR training funding and QR funding.

22. Annex B contains the criteria for inclusion of data in the allocations of per capita, premium, PGR training funding, race equality funding, well-being and health funding and targeted employability support funding.

23. Annex C contains the eligibility criteria for data used in the calculation of the National Measures.

24. Annex D contains documentation supplied to HEPs to support Fee and Access Plan sign off.

25. Annex E contains a summary of recommendations from previous internal audits.

Teaching funding

26. 2024/25 teaching funding comprises:

• Funding allocated through the credit based teaching funding method for part-time undergraduate taught provision;
• Per capita funding for full-time and part-time taught provision;
• Expensive subjects premium funding for full-time undergraduate provision;
• Higher cost subjects premium for full-time undergraduate provision;
• Access and retention premium funding for part-time undergraduate provision;
• Disability premium for all modes and levels of study;
• Welsh medium premium for part-time undergraduate provision and full-time undergraduate provision that qualifies for expensive subjects premium or higher cost subjects premium funding.

27. Funding allocated for part-time undergraduate provision through the credit based teaching funding method for 2024/25 was based on 2022/23 End of Year Monitoring of Higher Education Enrolments (EYM) credit value data extracted through the HESA Information Reporting Interface Service (IRIS) process. HEFCW circular W23/26HE details the 2022/23 EYM extraction process and mappings.

28. Adjustments to credit based teaching funding are normally calculated using EYM data extracted during the HESA IRIS process. The 2022/23 adjustment process has taken place and the data extracted is described in the 2022/23 EYM circular W23/26HE. The latest data extraction is described in the 2023/24 EYM publication Medr/2024/00 though the adjustments for 2023/24 have not yet been calculated.

29. Testing of the systems and processes used to generate figures returned on the Higher Education Students Early Statistics (HESES) survey and EYM data returned on the HESA student record and extracted via HESA IRIS should aim to answer the following questions:

• Is the latest HEFCW/Medr guidance being utilised and adhered to, in particular, have changes from the previous HESES surveys been noted and appropriately implemented?
• Are data on the records system validated (e.g. a comparison of a sample of enrolment forms with data on the system)?
• Is the method of extraction of data used to make a return to the HESES survey documented?
• Is there an adequate audit trail to confirm that the method of data extraction for the surveys is being applied as documented?
• Are details of any manual amendments to data extracted from the system for the HESES survey, or to EYM data extracted via HESA IRIS, documented, with justification and/or appropriate authorisation of the changes?
• Is a copy kept of the data taken from the system to make the return to the HESES survey?
• Is the final return to the HESES survey checked against data on the system prior to submission and is there adequate evidence of this checking process?
• Is the EYM data extraction provided through the HESA IRIS system checked against data on the HEP’s internal system and is there evidence of this checking process prior to the data verifications being signed off?
• Is the verification approved and signed off by an appropriate person?
• Are the staff resources available, taking into consideration experience and expertise, adequate to ensure that the HESES survey returns are accurately prepared and the EYM extraction from the HESA IRIS system is thoroughly checked?
• Is the documentation of the system and staff resource sufficient to ensure that accurate data returns could be prepared even in the absence of some key staff?
• Is there a risk register in place and are the risks relating to the compilation of accurate data returns, and related controls to manage these risks, adequately assessed and documented together with details of planned action to be taken, where relevant, to strengthen the existing controls?
• Where errors were identified in HESES/EYM returns or sign-offs, by HEFCW/Medr or the HEP, have processes been implemented to address these data errors and to mitigate against errors in future returns and sign-offs?
• Are HESES survey returns scrutinised before submission by suitably experienced members of staff other than those compiling the return?
• Are EYM data extracted as part of the HESA IRIS system scrutinised before verification by suitably experienced members of staff other than those that compiled the HESA return?
• Is a summary report of the data returned presented to the HEP’s senior management team (e.g. the total numbers of credits and students by mode and level with comparisons to prior years and/or other returns)?
• Is there a suitable process in place to ensure that staff who provide information (e.g. in departments) and staff compiling the return liaise as necessary to ensure that the most up to date information available relating to the survey period is included in the return?
• Is there evidence that validation and credibility checks are completed before returning or signing off data (e.g. scrutinising the credibility checks provided by HEFCW/Medr on the Excel spreadsheets; comparing EYM/HESES data against HESES returns made earlier in the academic year or in the previous academic year; use of control totals)?
• Has the Explanations worksheet in the EYM workbook been completed where year on year differences require explanations?
• Are there procedures for determining the fundability status of students and are checks made on fundability status (e.g. for students located outside Wales); and have the fundability rules contained in HESES been accounted for in the determination?
• Is the method for assigning Higher Education Classification of Subjects (HECoS) codes to modules and hence categorising credits into Academic Subject Categories (ASCs) documented and reasonable (for any data relating to 2019/20 onwards)?
• Is there an adequate audit trail to confirm that the method for categorising credits into ASCs is being applied as documented?
• Are processes used by HEPs to calculate estimates (e.g. non-completion rates) reasonable and documented, and is their reliability tested?
• Do processes ensure that evidence of enrolment and attendance available is complete and retained as part of the audit trail (e.g. enrolment forms, online enrolment records, module choice forms)?
• Are franchised out students correctly identified as such on the system, and recorded as such on the returns, and not, for example, as distance learning students (where distance learning students are those that are students of the reporting HEP, where staff employed by the reporting HEP are responsible for providing all teaching or supervision, but who are located away from the reporting HEP and are not part of a franchising arrangement with another HEP or organisation)?
• Are arrangements with franchise partners documented and are there controls in place to ensure that only the franchisor returns the provision?
• From 2024/25 HESES onwards, are degree apprentices on the Medr funded degree apprenticeship scheme recorded correctly both for enrolments and associated assumed completed credit values.
• If the HEP has recently been formed from a merger are the data systems in place sufficiently integrated to enable the HEP to make returns for the whole HEP and manage the process of validating and verifying data?

30. For 2024/25 funding, per capita and premium funding is based on data taken from the 2022/23 HESA student record (coding manuals and guidance are available on the HESA website – www.hesa.ac.uk). In looking at the above questions, in any in analysis of student data, it is not expected that auditors will look in depth at systems and processes related to 2022/23 HESA student record data, as described in paragraphs 6 and 14, but that any in depth testing carried out would be on the systems and processes for 2022/23 data used for 2024/25 funding.

31. HESES data is not used in allocation of 2024/25 teaching funding, however it is required to monitor student recruitment and to provide to the Welsh Government for student and, up to 2023/24 HESES, Initial Teacher Education (ITE) planning. Additionally, from 2024/25 onwards, HESES data is used in allocation of in-year funding for degree apprentices on the Medr funded degree apprenticeship scheme. Testing will be similar to that of the systems and processes of the EYM extractions and as described in paragraph 29.

Data Requirements

32. The fields and criteria used to extract data from the records for 2024/25 funding and monitoring of funding are detailed in the HEFCW Higher Education Data Requirements circular W23/27HE The HESA student record data used in 2024/25 funding and monitoring of funding in the main is 2022/23 data which was the first record collected since the implementation of HESA Data Futures.

33. In looking at the scope of the audit, in any in analysis of student data and the associated systems and processes, including the suggested testing below, it is expected that auditors will look at 2023/24 HESA student record data submission, using guidance included in paragraphs 6 and 14.

34. Testing of the systems and processes used to make these returns should aim to answer the following questions:

HESA student record:

• Do the controls include quality checks on individualised data prior to submission to HESA, in particular for data fields used in funding (e.g. checks that home postcodes have been correctly transcribed; HECoS codes are correctly assigned; fundability status is correct; year of student is correct; those in receipt of disabled students’ allowance (DSA) are recorded as such)?
• Where errors were identified in prior returns, by HEFCW/Medr, HESA or the HEP, through audit, in Medr/HEFCW data quality meetings or otherwise, particularly those which led to reductions in funding, have processes been implemented to address these data errors and to mitigate against errors in future returns?
• Have any issues that have been raised via the HESA Issue Management System (IMS) and any associated targets applied been collated and considered to make improvements in future data submissions?
• Where errors have been identified in prior returns, are the relevant data checked prior to final submission of data to HESA to confirm that the error has not reoccurred?
• Is there evidence that the web reports and IRIS output, produced by the HESA data returns system after committing data, are scrutinised, and that any resulting issues are addressed?
• Has a review of the implementation of HESA Data Futures been carried out and any updates to systems or processes been actioned along with any associated changes to risk registers?
• Is a copy kept of the final data submitted to HESA?
• Is the method used to calculate the proportion of a module taught through the medium of Welsh documented, reasonable and consistently applied?
• Are any manual amendments made by HEFCW/Medr to exclude Welsh medium modules checked to confirm they have been correctly excluded?
• Are any changes made to include additional information requested, or manual amendments made to the Degree Apprenticeship monitoring extracts, checked to confirm they are accurate and adjusted totals are correct?
• Are any manual amendments made by the provider to the monitoring returns output from IRIS for the part-time fee waiver and PGT Master’s bursaries documented and scrutinised before sign-off?
• Are the staff resources available, taking into consideration experience and expertise, adequate to ensure that the data returns are accurately prepared?
• Is the documentation of the system and processes and the staff resource sufficient to ensure that accurate data returns could be prepared even in the absence of some key staff?
• Is there a risk register in place and are the risks relating to the compilation of accurate data returns, and related controls to manage these risks, adequately assessed and documented together with details of planned action to be taken, where relevant, to strengthen the existing controls?
• Are returns scrutinised before submission by suitably experienced members of staff other than those compiling the return?
• Is a summary report of the data submitted to HESA presented to the HEP’s senior management team (e.g. numbers of students by mode and level and/or course and subject with comparisons to prior years and/or other returns)?
• Are the HEFCW/Medr confirmation and verification reports checked against data submitted to HESA to ensure that the HEFCW/Medr reports are accurate according to HEFCW/Medr criteria?
• Where, in addition to their directly funded provision, the FEI franchises provision in, are there controls in place to ensure that only the franchisor returns the provision to HESA?
• If the HEP has recently been formed from a merger are the data systems in place sufficiently integrated to enable the HEP to make a HESA student record return for the whole HEP?

National Measures

35. The systems and processes used to return data used in the monitoring of National Measures for 2017/18 and onwards, for HEIs, are within the scope of the audit for the following set of measures:

• Widening access;
• Participation;
• Retention;
• Part-time;
• Welsh medium;
• Student mobility;
• Continuing Professional Development;
• Total HE-BCI income per full-time equivalent (FTE) of academic staff;
• Spin off activity;
• Start – up activity (graduate);
• Research Staff;
• PGR students;
• PhDs awarded;Research income;
• EU/Overseas students;
• EU/Overseas staff;
• Transnational Education.

36. A subset of the National Measures are included in the scope of the audit for FEIs:

• Widening Access;
• Participation;
• Retention;
• Part-time;
• Welsh medium.

37. HESA UK performance indicator (PI) data, which are derived from HESA student record data, were used in the calculation of the participation and retention National Measures. HESA previously produced PIs on behalf of all the HE funding and regulatory bodies of the UK and announced that 2022 would be the last year that PIs would be published and indicators will be reviewed for migration into Official statistics or Open data. However at the present time there are no updates to the UK PIs used to monitor participation and retention. This means that 2020/21 academic year data were the last used to produce PIs in their current form. More information about the UK performance indicators can be found on the HESA website. While we are unable to update the retention measure for 2021/22 and 2022/23, we have been able to update the participation measure for both 2021/22 and 2022/23. HESA kindly provided us with the 2021/22 data calculated using the UKPI methodology as a one-off, and we have calculated 2022/23 using a methodology which follows HESA’s participation methodology as closely as possible.

38. The fields and criteria used to extract the data used in monitoring these measures are detailed in the Higher Education Data Requirements circular (HEFCW circular W23/27HE). Testing of systems and processes used to return data that are used in funding will cover most of the testing appropriate for HESA data used in monitoring National Measures. In any testing of the HESA student record, auditors should take note of the guidance in previous paragraphs relating to the 2023/24 HESA student record, particularly in paragraphs 6 and 14. In addition to the points in paragraph 34, testing should aim to answer the following questions:

HESA student record:

• Do the controls include quality checks on individualised data prior to submission to HESA, in particular for data fields used in monitoring (e.g. checks that the student’s mobility experience data is correct)?
• Is there evidence that for National Measures data extracts contained in the IRIS output produced by the HESA data returns system after committing data, is scrutinised, and that any resulting issues are addressed?

HESA Higher Education Business and Community Interaction (HEBCI) survey:

• Are HEBCI survey definitions and guidelines utilised and adhered to?
• Are validation and credibility checks carried out before returning data (e.g. comparisons with previous year’s data)?
• Are the methods and processes used to collate and extract data documented?
• Is there an adequate audit trail to confirm that data extraction methods are being applied as documented?
• Are the staff resources available, taking into consideration experience and expertise, adequate to ensure that the data returns are accurately prepared?
• Is the documentation of the systems and processes and the staff resource sufficient to ensure that data returns could be prepared even in the absence of some key staff?
• Is there a risk register in place and are the risks relating to the compilation of data returns, and related controls to manage these risks, adequately assessed and documented together with details of planned action to be taken, where relevant, to strengthen the existing controls?
• Are returns scrutinised before submission by suitably experienced members of staff other than those compiling the return?
• Is a summary report of the data returned presented to the HEP’s senior management team (e.g. the items of data used in Corporate Strategy targets with comparisons to prior years and/or other returns)?
• Is there a suitable process in place to ensure that staff who provide information (e.g. in departments) and staff compiling the return liaise as necessary to ensure that the most up to date information available relating to the survey period is included in the return?
• Are processes used to calculate estimates reasonable and documented, and is their reliability tested?
• If the HEP has recently been formed from a merger are the systems in place sufficiently integrated to enable the HEP to make a HEBCI survey return for the whole HEP?
• Do the controls include a reconciliation of the total amount of income recorded on the HE-BCI survey from collaborative research, consultancy, contract research, continuing professional development, facilities and equipment related services, intellectual property and regeneration and development returned with the audited accounts to ensure consistency?

HESA finance record:

• Are definitions and guidelines utilised and adhered to?
• Are validation and credibility checks carried out before returning data (e.g. comparisons with previous year’s data)?
• Are the methods and processes used to collate and extract data documented?
• Is there an adequate audit trail to confirm that data extraction methods are being applied as documented?
• Is a copy kept of the final data submitted?
• Are the staff resources available, taking into consideration experience and expertise, adequate to ensure that the data returns are accurately prepared?
• Is the documentation of the systems and processes and the staff resource sufficient to ensure that data returns could be prepared even in the absence of some key staff?
• Is there a risk register in place and are the risks relating to the compilation of data returns, and related controls to manage these risks, adequately assessed and documented together with details of planned action to be taken, where relevant, to strengthen the existing controls?
• Are returns scrutinised before submission by suitably experienced members of staff other than those compiling the return?
• Is a summary report of the data returned presented to the HEP’s senior management team (e.g. the items of data used in Corporate Strategy targets with comparisons to prior years and/or other returns)?
• Is there a suitable process in place to ensure that staff who provide information (e.g. in departments) and staff compiling the return liaise as necessary to ensure that the most up to date information available relating to the survey period is included in the return?
• Do controls include a reconciliation of the returned Research income values with the audited accounts to ensure consistency?

HESA Staff record

• Are quality checks carried out on individualised data for data fields used in National Measures (e.g. nationality, academic employment function)?
• Where errors were identified in prior returns, by Medr/HEFCW, HESA or the HEP, through audit or otherwise, have processes been implemented to address these data errors?
• Where errors have previously been identified in data used in National Measures, are the data checked prior to final submission of data to HESA to confirm that the error has not reoccurred?

HESA Aggregate Offshore Record

• Are quality checks carried out on headcount data used in the Transnational Education National Measure?

PGR and QR Funding

39. More information about the funding methodology for both the PGR training funding allocation and the QR funding allocation, which were revised in 2022/23, can be found in circular W22/24HE.

40. PGR training funding for 2024/25 was allocated using data about eligible, fundable student FTEs in REF 2021 units of assessment (UoAs) which qualified for QR funding taken from the 2022/23 HESA student record. Students eligible to be included in the calculation of PGR funding are those in REF 2021 units of assessment (UoAs) that were included in the QR funding model for 2022/23.

41. The fields and criteria used to extract the data from the record for 2023/24 funding are detailed in the Higher Education Data Requirements circular Medr/2024/01. In any testing of the HESA student record, auditors should take note of the guidance in previous paragraphs relating to the 2023/24 HESA student record, particularly in paragraphs 6 and 14. In addition to the points in paragraph 29, testing should aim to answer the following questions:

HESA student record:

• Are quality checks carried out on individualised data for data fields used in calculating PGR funding (e.g. fundability status is correct; UoA is correct; student FTE is correct; postcode and domicile are correct)?
• Are the Medr confirmation reports checked against data submitted to HESA to ensure the Medr reports are accurate according to Medr criteria?
• Where errors were identified in prior returns, by Medr, HESA or the HEP, through audit or otherwise, particularly those which led to reductions in PGR funding, have processes been implemented to address these data errors and to mitigate against errors in future returns?
• Where errors have previously been identified in PGR data, are the PGR data checked prior to final submission of data to HESA to confirm that the error has not reoccurred?

42. Following the implementation of the new funding methodology for QR funding allocations for 2022/23, all input data were frozen. Therefore data used to calculate 2024/25 QR funding remain the same as those used to calculate 2022/23 QR funding. Data used to calculate 2022/23 QR funding were taken from REF 2021, and from the 2018/19, 2019/20 and 2020/21 HESA finance record . The REF 2021 is not included in the scope of the audit.

43. Checks on the systems and processes used to return data relating to the student finance data from the particular years used in the QR funding allocation are included in the scope, only where they have not been included in previous audits and this is considered to be an area of risk. The questions these checks should aim to answer are outlined in the section above.

Research Wales Innovation Fund (RWIF)

44. This funding stream is calculated using data from the HE providers HESA HEBCI survey and from their HESA staff, student and finance records.

45. The details of this process can be found in HEFCW circular W23/12HE and the allocations for 2024/25 are outlined in HEFCW circular W24/13HE. Testing should aim to answer the following questions (in addition to those listed for other funding streams above):

HESA student record (Open University in Wales only):

• Do the controls include quality checks on data prior to submission, in particular for the data fields used for RWIF (e.g. that student FTE is returned correctly)?

HESA Higher Education Business and Community Interaction (HEBCI) survey:

• See the HEBCI questions in paragraph 38.
• Do the HEBCI values signed off during the RWIF verification frequently differ from those values submitted to HESA?

HESA finance record:

• See the HESA finance record questions in paragraph 38.

HESA Staff record

• Are quality checks carried out on data for data fields used in this return (e.g. that academic Staff FTE is returned correctly)?

Data returned on fee and access plans and fee and access plan monitoring returns

46. Fee and Access Plans covering two years were submitted in 2024. The approved plans covered the 2025/26 and 2026/27 academic years.

47. Fee and Access Plans were returned in line with guidance included in HEFCW circular W24/07HE Fee and Access Plan guidance. Data required for HEI submissions were limited to total numbers of students forecasted for study at each of the institutions’ location of study. Detailed guidance for this can be found in paragraphs 157 to 165 in HEFCW circular W22/19HE. In addition to this, FEIs were required to submit information on total fee income to be received and financial information. Guidance for this can be found in W22/19HE in paragraphs 155-156 and 166-173 respectively.

48. Institutions were invited to provide applications for Fee and Access Plan variations in March 2024 further to an increase in tuition fee limits made by Welsh Government in February. As part of that process, institutions were required to submit a tracked change version of their original Plan, alongside a variation request form. In submitting the variation, governing bodies of those institutions were confirming that they:
i) were compliant with CMA requirements and have taken appropriate legal advice;
ii) had consulted students on the variation;
iii) involved student representatives in the approval process;
iv) would continue to invest their agreed proportion of tuition fee income with no reduction to the proportion of investment to promote equality of opportunity; and
v) had involved partner providers where fee levels are being varied at courses delivered under franchise arrangements.

49. Fee and Access Plan monitoring is incorporated into the annual assurance return process. Institutions’ governing bodies are required to sign off the following statements in relation to Fee and Access Plans:

• No regulated course fees have exceeded the applicable fee limits, as set out in the 2023/24 Fee and Access Plans.
• The institution has assurances in relation to the management of the provision of fee information across all recognised sources of the institution’s marketing.
• The institution has taken all reasonable steps to comply with the general requirements of the 2023/24 Fee and Access Plans.
• The institution to provide documentation to support Fee and Access Plan sign off.
• The institution has taken all reasonable steps to maintain previous levels of investment, including maintaining:
  • the splits between investment to support equality of opportunity and promoting higher education,
  • investment to support the Reaching Wider partnership and student support investment.

50. The documentation produced internally that enables the governing body to sign off its annual assurance statement must be submitted alongside the annual assurance return. These documents enable us to understand the basis on which the governing body was able to sign off the Fee and Access Plan related statements of the annual assurance return. In addition to this, we also require documentation to be submitted to evidence how institutions evaluate the effectiveness of investment to deliver on Fee and Access Plan objectives. Auditors should familiarise themselves with the data required to enable the governing body to sign off this part of the statement and to inform the evaluation of the effectiveness of the Fee and Access Plan. Guidance to inform institutions is provided at Annex D.

Other HESA data

51. Other HESA data not covered in the previous paragraphs that are also under the scope of the audit include data returned on the HESA finance record, aggregate offshore record, Estates Management record, HEBCI survey and data returned on the HESA Unistats record.

52. Testing of systems and processes used to return data that are used in National Measures and RWIF funding (see relevant sections above) will cover most of the testing appropriate for HESA HEBCI survey data and HESA finance record data.

53. The Unistats dataset contains information about courses. Included in the scope of an audit of Unistats data are course related data and accommodation cost data. Testing should aim to answer the following questions:

• Have eligible courses been returned on the Unistats dataset and are the data for those courses accurate?
• Where data have been estimated, have estimates been made on a reasonable basis and documented?

54. The following funding streams were also allocated:

• Higher Education Research Capital (HERC) Funding 2024/25 (W24/14HE)
• Capital Funding 2024-25 (W24/12HE)

The audit of systems and processes used in other funding streams is sufficient to also provide assurance for the funding streams listed in this paragraph.

HESA Data Futures Programme

55. Data Futures is Jisc’s transformation programme for collecting student data, and was implemented for the 2022/23 HESA student record collection.

56. The 2022/23 and 2023/24 collections were an annual collection using the Data Futures data model. The 2024/25 collection will continue to be an annual collection.

57. Auditors should familiarise themselves with the programme and the requirements for the new record from 2022/23 and into 2023/24. We recommend that any review of the 2023/24 HESA student record should follow the guidance as described in paragraph 6, given the continuing difficulties that providers encountered in returning the record. We would expect auditors to provide opinions on the controls in place to manage risks relating to the record going forward including plans to review and/or improve processes, documentation and data quality using lessons learnt from the return of both 2022/23 and 2023/24 data, moving into the 2024/25 return, even if those processes or plans are not yet in place.

58. Testing should aim to answer the following questions:

• Did the HEP have sufficient resource, in terms of both finance and suitably skilled staff in making the 2023/24 return?
• Were senior management aware of any issues that their provider encountered for the 2023/24 return?
• Is there a plan in place to review any data quality issues, targets set resulting from IMS queries, or to put in place any lessons learnt from the 2022/23 and 2023/24 returns, to improve future returns?

Interpretation and Guidance

59. Auditors should familiarise themselves with the latest, at the time of audit, HESES, EYM, HESA guidance (including for the HEBCI survey and finance record), data requirements circular and where available, the fee and access plan process and guidance. Some of the publications may be updated after publication of this publication and auditors should pay particular attention to any changes made to the data collected that imply changes to the way in which systems and processes work and assess whether HEPs have made or intend to make appropriate adjustments.

60. Any further clarification relating to the guidance for making HESES, EYM, HESA returns or extracting EYM data from the HESA student record via the IRIS system or relating to fee and access plan guidance can be obtained from Medr via [email protected].

Open University in Wales

61. Medr has responsibility for some funding relating to teaching and RWIF at the Open University (OU) in Wales. Teaching and RWIF funding allocated to the OU in Wales is calculated using the same funding methodology as other HEIs. As in previous years the systems and processes used to compile data returns to HESA and Medr that are used in the calculation of teaching and RWIF funding are included in the scope of the internal audit. In addition, the OU in Wales is included in the National Measures and so the systems and processes used for monitoring these are included in the scope of the audit. The OU in Wales does not currently receive PGR or QR funding from Medr and as the OU are not a Medr regulated institution, do not submit a fee and access plan.

Reporting

62. The annual internal audit plan should include a review of the controls in place to manage the risks relating to the submission of accurate data returns and where appropriate, data returned in and used to monitor the FAPs.

63. This review should include an assessment of the adequacy of the controls documented in paragraphs 29 to 58 above as relevant. However, the precise scope of the internal audit work completed will be determined by each HEP’s assessment of the risks relating to their HEP’s data return and it is expected that the internal audit work will focus on the higher risk aspects of the systems and processes, for example, issues identified in previous audits, or aspects not covered in previous audits. It is expected that the scope would address any data issues or errors found by the HEP or HEFCW/Medr in terms of processes in place to correct the errors and to mitigate against any future errors. In assessing the risks, we would expect the HESA student record return for 2023/24 to be an area of risk, however, providers should take account of the guidance provided in paragraphs 6 and 14 in relation to the 2023/24 record when determining the scope of the audit work.

64. The timing of the internal audit work should be arranged so that the internal audit report can be completed and presented to the HEP’s Audit Committee before a copy of the report is sent by the HEP to Medr by 27 June 2025.

65. Where the Audit Committee’s internal audit plan includes only very limited work in relation to data systems and processes, because there is perceived to be low risk in this area, an institutional representative should contact Medr to inform us why this area is considered low risk and how annual assurance can be obtained in these circumstances. The representative should contact Medr at the point that their Audit Committee finalises their audit plan if this is the case. Similarly, if there are any changes to the cyclical nature of the plan or timing of committees that mean that an audit report will not be available by the deadline of 27 June 2025, a representative should contact Medr to discuss.

66. The internal audit report should include:

• A description of the objectives of the audit and the risks and controls included within the scope of the audit;
• Details of the audit work completed;
• Details of issues identified during the audit and the recommendations made to address these;
• Details of processes put in place to correct the errors and to mitigate against any future errors of any data issues or errors found by the HEP or HEFCW/Medr;
• A consideration of the recommendations made in previous audit reports and the extent to which these have been effectively implemented;
• Management’s responses to the report’s recommendations and the agreed timescales for their implementation;
• Details of any disagreements or recommendations which were not accepted by management;
• A clear conclusion and overall opinion as to the adequacy and effectiveness of the controls in place to manage the risks relating to the accuracy of the data returns included within the scope of the audit.

67. If the internal audit report’s overall conclusion, or the conclusions relating to the adequacy of the design of the system of control and the application of those controls, provides a negative opinion (e.g. limited or no assurance, unsatisfactory or inadequate controls) details of the significant exceptions giving rise to this opinion should be provided in the report. In these circumstances the HEP’s Audit Committee and Medr should be informed of the relevant issues as soon as possible.

68. The HEP’s Audit Committee should include reference in its annual report to the reports and assurances that it has received during the year in respect of the controls in place to manage the quality of data returns made by the HEP for funding or monitoring purposes and the controls relating to data returned in and used to monitor the fee and access plans.

69. An electronic copy of the audit report and any associated correspondence should be sent by the HEP to [email protected] no later than 27 June 2025. Note that we do not require a paper copy to be sent to us.

70. Details of the internal audit work and reports completed since the last external audit of higher education data should be retained and if required be made available to any external auditors as advised by Medr. The Medr Audit Service may also wish to review these reports and related papers during their periodic visits to the HEP.

Further information

71. Further guidance and information is available from Rachael Clifford or Hannah Falvey ([email protected]).

Medr has today welcomed its first advice from the Coleg Cymraeg Cenedlaethol on its duties relating to the Welsh language, reflecting their shared ambitions to encourage the demand for, and the participation in, tertiary education provided through the medium of Welsh.  

The advice, published by the Coleg, follows the Coleg’s designation to advise Medr, on its duty to promote tertiary education through the medium of Welsh, and has been considered in detail by our Board.  

The Coleg’s advice sets out steps that Medr and the tertiary education sector should take in supporting the Welsh Government’s ambitions for the Welsh language and the goals of Cymraeg 2050. This includes a central recommendation that Medr should develop a National Plan for the Welsh language across the tertiary education sector, which the Medr Board has agreed.

Medr’s Strategic Plan will be submitted to Welsh ministers in December 2024. The advice from the Coleg, combined with engagement across the tertiary education sector, has played a crucial role in shaping how Medr will respond to its strategic duties to the Welsh language.

Simon Pirotte OBE, Chief Executive Officer of Medr, said: “The relationship with the Coleg Cymraeg Cenedlaethol is of vital importance to Medr. We are united in our desire to see the Welsh language thriving in Wales, and committed to ensuring the tertiary education sector plays its part in realising a vision for a million speakers in Wales by 2050. The advice we have received marks the start of a significant new phase of working together, building on the positive foundations we have already established. A National Plan will be a crucial driver in enabling more learners to develop, maintain and use their Welsh language skills.”

Medr will continue to fully take account of the Coleg’s advice as it implements its Strategic Plan 2025-2030 in partnership with all stakeholders.  

Introduction

1. This publication requests higher education institutions and further education institutions with higher education provision (known collectively as higher education (HE) providers) that are funded directly by Medr for HE provision to return aggregated student data to enable Medr to:
a). Have early indications of the number of students in the academic year 2024/25;
b). Monitor recruitment of full-time (FT) undergraduate (UG) and postgraduate certificate in education (PGCE) students covered by the fee and access plans;
c). Fund and monitor degree apprenticeship provision under the Medr degree apprenticeship scheme.

Note that this request does not include the six new subscribers to the Higher Education Statistics Agency (HESA) who have specifically designated HE course provision.

Main changes for 2024/25

2. The main changes made since the HESES 2023 survey are:
a). The survey dates are earlier than the 2023/24 survey and are more in line with previous surveys;
b). Tables 2a to 2c are no longer collected. Consequently, the table labelled Table 3 in 2023/24 is now labelled Table 2;
c). The maximum fee limits for full-time undergraduate and PGCE courses have been updated. See Annex F;
d). Annex K (previously labelled Annex J) has been updated to reflect the mapping that is being used in the extraction of data for end of year monitoring for 2023/24;
e). An additional table is being requested, Table 3, which collects information relating to degree apprenticeships. The information collected will be used to calculate funding for and monitor degree apprenticeship provision funded under the Medr scheme. The inclusion of this table was consulted upon in Medr publication, Medr/2024/02: Higher Education Students Early Statistics – consultation on changes for 2024/25 collection of Degree Apprenticeship in-year data. There was support to use the HESES survey to collect this information. Annex I gives guidance relating to the return of degree apprenticeship data. Other annexes have been updated to reflect the inclusion of this new table and relabelled where appropriate. The responses and outcomes of the consultation can be found in Annex O.

Survey data

3. HE providers that are directly funded by Medr for their HE provision are requested to return numbers of HE students on Tables 1 and 2. These are students registered on prescribed HE courses leading to recognised HE qualifications (see Annex B). HE providers that have degree apprenticeships funded under the Medr scheme (previously the HEFCW scheme) are requested to return numbers of students and credit values related to those apprenticeships on Table 3.

Contents

4. This circular provides:
a). Guidance and definitions for the various categories used to classify students;
b). Rules for counting registrations;
c). Rules for counting credit values for degree apprenticeships; 
d). Details of the criteria we will use to extract data from the HESA student record for end of year monitoring and to get information collected on previous HESES surveys;
e). Copies of the survey tables which will be distributed in Excel workbooks for providers to complete and return.

5. The contents of the annexes are as follows:

Annex		Page number
Annex A	Summary guide to the HESES 2024/25 survey	5
Annex B	Definition of a recognised HE qualification	14
Annex C	Distance learning, campuses, subsidiaries, franchises and other collaborative arrangements	15
Annex D	Definition of residential and funding status	22
Annex E	Definition of ASCs	26
Annex F	Definition of mode of study	28
Annex G	Definition of level of study	31
Annex H	Rules for counting registrations	33
Annex I	Guidance for the return of degree apprenticeship data	42
Annex J	Table and column descriptions	48
Annex K	HESA/HESES mappings and end of year monitoring data extraction criteria	51
Annex L	Workbook notes	61
Annex M	Validation checks	63
Annex N	Usage of data by Medr	64
Annex O	Outcomes of degree apprenticeship consultation	65
Annex P	Funding status reference grid	69
Annex Q	Sample copies of tables for completion by all providers directly funded by Medr for HE provision	71

Return of data

6. Providers are required to notify Medr of student registrations for the whole year, apart from on Table 3, which collects student registrations for the whole year for continuing students, student registrations between 1 August 2024 and 1 November 2024 inclusive for new entrants, plus associated credit value data for entrants on or after 1 August 2022.

7. The completed degree apprenticeship table (Table 3) should be returned by email to Andrea Thomas at [email protected] no later than 18 December 2024. Completed workbooks for the whole survey, should be returned by email to Andrea Thomas at [email protected] no later than 30 January 2025.

8. Providers that do not have degree apprenticeship provision funded under the Medr scheme are not required to return Table 3 by 18 December 2024.

9. Providers are encouraged to begin to prepare their returns well before the return date so that only final adjustments need to be made before dispatch of the completed returns.

10. It is important that the whole survey return is made on time so that early indications of numbers of students for 2024/25 are available, and to ensure that Medr has sufficient time to complete the checking process prior to sending out verifications for sign off.

11. We request that providers let us know as soon as possible, and before the return dates of 18 December 2024 for degree apprenticeships information or 30 January 2025 for the whole survey, if they envisage that they will have difficulty returning the required information or if they will have difficulty meeting the timetable given in paragraph 12. This includes ensuring that the authorised signatory, or the alternative authorised signatory, is available to sign off the verifications by the due dates. Medr reserves the right to enter its own estimates of student registrations and credit values for providers which fail to return the survey or sign off the data on time, or where data are considered to be of insufficient quality.

12. When data are returned, we carry out a validation and credibility checking process. Once any subsequent queries have been resolved, data are sent out to authorised signatories at providers for verification. The process will follow the timetable outlined below.

Table 3:

18 December 2024	Return deadline
10 January 2025	Verifications sent to providers
24 January 2025	Verifications return deadline

All HESES tables:

30 January 2025	Return deadline
13 February 2025	Verifications sent to providers
5 March 2025	Verifications return deadline

13. In the event of a deadline being missed without prior agreement, we will contact the HESES data contact and/or authorised signatory to request an explanation. If a deadline is missed by more than three working days, without prior agreement, we will email the head of the provider, reminding them that Medr reserves the right to enter its own estimates of student registrations for providers which fail to return the survey on time and indicating that Medr intends to do this if immediate action is not taken. Failure to return the data or verification report within two working days of the email will result in a letter from the Chief Executive of Medr to the head of the provider stating the figures that will be used in place of the provider’s own data.

14. Signed verifications should be returned by emailing them to Andrea Thomas at [email protected]. Prior to returning the signed verifications to Medr, providers must have undertaken sufficient checks to be satisfied that the returned data are accurate. Data anomalies queried by Medr must have been corrected or, if genuine, must have an associated explanation. Any changes that are made to the verification before signing and returning, that are not already made to the Excel format, should also be submitted in an Excel format.

15. Each subsequent deadline should be met regardless of any delay in meeting the preceding deadline.

16. Data extracted and signed off as part of the 2023/24 Information Reporting Interface Service (IRIS) process^[1] when providers make a submission to HESA, will be used in funding allocations. Providers should note that the data extractions at IRIS may need to be supplemented with additional data extractions once the methods for teaching funding for 2025/26 are finalised. If this is the case, we will contact providers about the sign off process for any additional data needed, not already signed off as part of the IRIS data extraction process. Further details are provided in the 2023/24 EYM publication and the data requirements publication for 2024/25.

17. Providers are reminded that data returned to Medr on the HESES survey, including methods used to calculate any estimates included in the returned figures, may be subject to an external audit carried out by Medr or by contractors working on Medr’s behalf. The systems and processes used to generate HESES data are in the scope of providers’ internal audits.

Future developments

18. The Statistics and Data area of the Medr website provides information about data collection. If providers have suggestions of anything additional they would like to see included, they should contact Medr at [email protected].

Further information

19. Any queries should be directed to Andrea Thomas ([email protected]).

^[1] Medr website: Data and analysis

Wales Research Environment and Culture

1. The development and sustainability of healthy research cultures and environments in universities is pivotal to supporting excellent research. Research funding bodies in the UK are supporting positive cultures through wide-ranging capacity building and enhancement activities, alongside piloting the assessment of People, Culture and Environment within the Research Excellence Framework 2029.

2. We are ambitious for our research sector in Wales. We want Wales to be renowned as a great place to undertake research and which, through collaboration, secures social, economic and cultural benefits.

3. We cannot do this without supporting the diverse workforce who contribute to research. We want to encourage research environments that support integrity, diversity, inclusivity, well-being and respect, attracting and retaining talented people from Wales, UK and across the world.

4. In 2023 HEFCW initiated the WREC Fund recognising the need to enhance research culture activities already underway in universities, supported via QR funding allocations. Medr has reviewed the WREC monitoring returns received from universities in July 2024 which indicate the fund has been valued and contributed to new or enhanced activities. We propose to continue to support the funding until 2027/28 subject to future budgets.

5. This funding will provide dedicated support for enhancing research cultures and environments. However, Medr expects that a healthy culture should be treated as an integral part of research and innovation activity and also supported strategically through core research and innovation funding.

6. The allocation of £200,000 funding to Welsh universities is to support projects, programmes and activities that actively contribute to supporting or developing positive and healthy research cultures and environments.

7. Medr expects the funding to demonstrate progress and enhancement of activity related to research culture. This funding could be used to extend existing projects, and also for new activities and infrastructure.

8. For this second year of funding, we would encourage institutions to consider how they will measure and evaluate the impacts of their research culture activities. This is to ensure that the activities are making tangible changes to research culture or generating learning about what works. We realise that these enhancement activities may still be in their infancy, therefore in this academic year we are interested in how institutions are putting in place early-stage evaluation activities.

9. In determining the use of allocations, institutions should refer to the three themes outlined in the table below. These are based on themes developed through engagement with the Welsh and UK research sectors. This is not an exhaustive list and institutions are encouraged to use the funding flexibly accounting for their strategic priorities, and broader principles relating to improving research cultures and environments.

Themes	Potential sub areas of alignment
Creating Positive Research Culture(s)	* Reward and recognition of positive behaviours * Identifying what a positive research culture looks like including well being * Valuing diverse research activity * Career development of researchers and associated professions * Developing research culture frameworks * Improving infrastructure and capacity to support better research grant capture * Tackling bullying and harassment * Collegiality and belonging * Valuing the full range of experiences, skills and contributions of all who contribute to research
Embedding Equality, Diversity and Inclusion (EDI)	* Understanding and addressing barriers to inclusion for applicants from under-represented groups in the research talent pipeline with a view to ensuring the research environment is accessible, inclusive and equitable for all * Recognition of all staff contributions * Enhancing access to, and participation in, research from underrepresented groups
Responsible Research	* Integrity, openness and ethics * Improving research conduct and reproducibility * Research assessment and reform * Collaboration and convening institutions to share practice * Reproducilbility of metrics

10. Medr expects the WREC funding to be used to address barriers to inclusion of under-represented groups in the research talent pipeline and to develop a supportive and inclusive research environment, which values the contribution of academic staff, research enabling and support staff, and professional services staff. This includes, but is not limited to, technicians, archivists, and software engineers.

11. Medr encourages the use of the Welsh language in research to fully foster a rich and inclusive environment reflecting the cultural heritage of Wales, enriching the research community.

Sharing learning and good practices

12. Medr recognises the importance of collaboration across the sector in developing positive research cultures and the role of organisations such as the Wales Innovation Network (WIN), the Learned Society of Wales, and Universities Wales. We have provided £50,000 for FY 2024-25 to WIN to support sharing of good practices across institutions in Wales. We are also working in partnership with LSW to continue supporting diverse communities to effect change. Eligible universities are strongly encouraged to work collaboratively and build on existing activities that support positive research cultures for example: Researcher Development Programme – The Learned Society of Wales. We welcome ideas and feedback on further opportunities to support shared learning and collaboration.

Institutional Allocations

13. The method used to allocate funding for 2024/25 is based on 2022/23 HESA staff and student data:
* Number of FTEs on research-only contracts at the higher education institution
* Number of FTEs on teaching and research contracts at the higher education institution
* Number of postgraduate research students at the higher education institution

14. A minimum of £5k has been included to ensure that all universities have a usable allocation to enhance their research cultures and environments. HESA data used have been verified by universities.

Institution	FTE Research Contracts	FTE Teaching and Research Contracts	FTE PGR Students	Total	Allocation
University of South Wales	70	716	226	1012	£20,042
Aberystwyth University	118	287	257	1012	£13,120
Bangor University	224	261	610	1095	£21,683
Cardiff University	909	1312	1604	3825	£75,722
University of Wales Trinity Saint David	38	343	448	830	£16,442
Swansea University	438	549	676	1663	£32,994
Cardiff Metropolitan University	27	559	171	757	£14,996
Wrexham University	3	184	49	236	£5,000
Total	1,827	4,213	4,041	10,080	£200,000

15. This method was used by HEFCW for allocations in 2023/24 and was broadly supported by institutions in the consultation in December 2023. Medr notes that WREC funding allocation methodology does not explicitly include research-supporting staff such as some of the technical community, and professional services staff. Medr recognises the crucial contributions of these staff to research cultures and the research environment.

WREC Fund Monitoring Arrangements

16. Institutional allocations for AY 2024/25 will be made in November 2024. Medr expects assurances concerning the projects and activities that are being undertaken through this fund. Allocations should be spent in full in AY 2024/25.

17. Institutions should complete the WREC funding monitoring form at Annex A by 26 September 2025:
* Part 1 – Strategic Context: indicate the strategic context of research culture at your institution.
* Part 2 – Thematic Areas: should indicate how the activities/projects align with the thematic areas outlined in the Institutional WREC Funding section of this publication, and whether: 1. activities would have taken place without the funding, 2. activities only took place through WREC funding provision, or 3. activities could have taken place without the funding, but to a lesser extent.
* Part 3 – Evaluation: should explain how you plan to measure the effectiveness of the projects/activities.
* Part 4– Confirmation: confirm that the WREC funding has been spent in accordance with the information outlined in this publication.

18. Information submitted by institutions in their reports will form the basis of evidence to support future budget decisions and support for research culture and research environment across Wales.

Further information

19. For further information, contact Hayley Moss ([email protected]).

Impact Assessment

20. We have carried out an impact assessment to help safeguard against discrimination and promote equality. We anticipate a positive impact on race, sex, disability, age, religion and belief. We also considered the impact of this policy on the Welsh language, Welsh language provision within the HE sector in Wales, socio-economic characteristics and potential impacts towards the goals set out in the Well-Being of Future Generations (Wales) Act 2015.

21. We welcome the submission of monitoring reports in Welsh.

Introduction

1. This publication provides Medr guidance and monitoring templates for the allocation of £2m funding to universities to implement well-being and health strategies for 2024/25 (universities only) and for the allocation of an additional £2m in 2024/25 to well-being and health, including additional financial support for higher education students (universities and directly funded colleges).

2. This publication builds on guidance previously issued by HEFCW, in support of Medr’s aim to ensure a smooth transition for providers and learners in the first instance, as Medr takes on its new duties and responsibilities. Until the implementation of the new registration system for higher education providers, Medr has inherited HEFCW’s powers for funding and regulation of higher education.

Medr’s duties and responsibilities

3. Medr, the Commission for Tertiary Education and Research, became operational on 1 August 2024 after the dissolution of the Higher Education Funding Council for Wales (HEFCW) on 31 July 2024.

4. Medr has a strategic duty to promote equality of opportunity in tertiary education and will introduce a staff and student/learner welfare related condition of registration. The Tertiary Education and Research (Wales) Bill: Exploratory Memorandum notes: “The initial and ongoing conditions regarding support for and the promotion of student and staff welfare will introduce new regulatory requirements for providers which, it was envisaged, would encompass matters such as mental health, wellbeing and safety of learners and staff at the provider. The Commission will be required to set out and publish requirements which must be met by registered providers regarding their arrangements in respect to the initial and ongoing conditions. In the context of student and staff welfare, it is envisaged that ‘arrangements’ would include policies, procedures and support services for student and staff wellbeing and safety. ‘Wellbeing’ in this context is intended to mean emotional wellbeing and mental health. ‘Safety’ is intended to mean freedom from harms including harassment, misconduct, violence (including sexual violence), and hate crime.

5. In 2024, Welsh Ministers published their statement of strategic priorities for tertiary education and research and innovation that include a priority for Medr to create a common framework for mental health and well-being support across tertiary education.

6. Medr is required to prepare a strategic plan setting out how it will address the priorities and how it will discharge the strategic duties given to it under the Tertiary Education and Research (Wales) Act 2022.

7. In September 2024, Medr published its Strategic Plan consultation. The final version of the plan must be submitted to the Welsh Ministers for approval by 15 December 2024. The Commission is under a duty to publish its approved plan and take all reasonable steps to implement it.

8. The draft Strategic Plan includes a founding commitment for Medr to develop a common framework for mental health and well-being by 1 August 2026, affirming equality of opportunity and strengthened by regulatory conditions to support staff and learner welfare.

9. When developing and revising their well-being and health strategies, suicide safer approaches and well-being policies, we expect universities to take account of the following publications, policy and funding developments and, where appropriate, include related-actions in their 2024/25 implementation plans.

University well-being and health, including mental health, policy, funding and research update and our expectations arising from them

10. In February 2024, the Welsh Government consulted in its draft mental health and well-being strategy.

11. In July 2024, Universities UK published its report Enabling Student Health and Success: Tackling supply and demand for drugs and improving harm reduction.

12. In 2024/25 Medr continues to fund:
a). the student mental health service model development project. Medr are providing in 2024/25 additional funding to support the development of a data storage solution, continued rollout of the severity index and exploration and development of information sharing protocols.
b). Myf Cymru to provide Welsh language student well-being resources and practitioners network.
c). the national Student Space programme with online student well-being materials available in Welsh.

Well-being and health, including mental health, wider equality and intersectionality considerations

13. The Welsh Parliament Health and Social Care Committee published its Connecting the dots: tackling mental health inequalities in Wales report with 27 recommendations. In February 2023 the Welsh Government published its response to the report.

14. Universities should consider the report recommendations when developing their well-being and health/mental health approaches including:
i). Trauma-informed Practice Framework that will be a key component in the Welsh Government’s drive to make Wales a trauma-informed nation.
ii).  The Welsh Government’s national framework for social prescribing.

15. In March 2023, HEFCW published circular W23/06HE: Safe and inclusive higher education: supporting equality and diversity education. The circular set out specific actions Welsh Government and/or HEFCW expected universities and regulated colleges to take and drew attention to:
* The Welsh Government’s LGBTQ+ Action Plan for Wales;
* The Welsh Government’s Violence against women, domestic abuse and sexual violence: strategy 2022 to 2026 and its Violence against women, domestic abuse and sexual violence: blueprint high level action plan;
* The Welsh Government’s Anti-Racist Wales Action Plan;
* HEFCW’s race, access and success policy developments; and
* HEFCW’s Well-being and health, including mental health policy developments.

16. During 2023/24, TASO published the following reports:
* What works to tackle mental health inequalities in higher education;
* Student wellbeing over time: analysing Student Academic Experience Survey data for undergraduates and taught postgraduates;
* Student mental health in 2023: Who is struggling and how the situation is changing.

17. The TASO Student well-being over time report found evidence to suggest that the following groups of students are at greater risk of poor mental health:
* Students from households with low economic status
* Students from Black, Asian, and Minority Ethnic backgrounds
* Mature students
* Students who are lesbian, gay, bisexual, transgender, queer/questioning or have other sexual identities (LGBTQ+) and
* Care-experienced students.

18. In July 2024, the Equality and Human Right Commission (EHRC) published an advice note for the higher education sector arising from the legal case of University of Bristol vs Abrahart. Universities must take account of the information provided in the note, particularly in relation to what the EHRC now considers compliance with the law looks like based on the court findings.

19. In September 2024, the Student Space programme published online resources on navigating university life as a Black student. The content was co-created by experts with lived experience and a steering group of Black students.

20. When developing and revising their well-being and health strategies, suicide safer approaches and well-being policies, universities must consider equality and intersectionality, conduct equality impact assessments and where appropriate include related actions in their 2024/25 implementation plans.

Well-being and health funding strategies and implementation plan funding 2023/24 (£2m, universities only)

21. We expect implementation plans in 2024/25 to continue to take a ‘whole university approach’, supporting and addressing the needs of staff and students and taking account of all aspects of university life, including living and working life. Where universities choose to fund well-being and health, including mental health activity and services from non-Medr funding, please include these activities and services and the sources of funding in the plans.

22. Universities should also consider supporting the transition, progression and success of applicants and students, as this relates to well-being and health, including mental health, working in partnership with schools, colleges and other external partners.

23. 2024/25 implementation plans should account for the university’s 2024/25 funding allocations (£2m strategy funding and £2m hardship funding) and any additional resources provided from non-Medr sources and include:
i). well-being and health, including mental health, strategy objectives/intentions being prioritised in 2024/25:
ii). activities, services, training, and resources, against the objectives/intentions, including dates by when new or continuing activities, services and resources will be established and/or completed;
iii). activities, services, training and resources provided bilingually and/or separately in Welsh;
iv). activities, services, training, and resources including students at franchise/partner organisations;
v). activities, services, training, and resources for postgraduate students;
vi). activities, services, training, and resources for international students;
vii). activities, services, training and resources to secure the well-being and health of staff and students, including health affected by harassment, hate and sexual misconduct and violence, regardless of identity ;
viii). activities, services, training and resources provided specifically to, or providing information about supporting,  staff and students with protected characteristics;
ix). activities, services, training and resources that take account of the Universities UK (UUK) Stepchange: mentally healthy universities self-assessment findings and recommendations;
x). clearly identifiable actions to address gaps, priorities or recommendations identified as a result of the university’s review using the UUK self-assessment tool;
xi). confirmation of how progress against the implementation plan will be monitored and measured;
xii). an explanation of how a representative range of students, staff and interested parties have been involved in developing the plan;
xiii). an explanation of how impact assessment findings have informed the objectives/intentions, activities and services to be delivered;
xiv). an explanation of how the implementation plan’s monitoring and review will be reported to and through university governance structures.

24. In addition, we expect implementation plans to take account of equality and intersectionality through the use of equality impact assessments, including but not limited to the following groups of students:
* Disabled students and students with long-term health conditions
* International students
* LGBTQ+ students
* Postgraduate students
* Students from Black, Asian, and Minority Ethnic backgrounds
* Students from a lower socio-economic background
* Students with caring responsibilities / returning after a break in education.
* Care-experienced students.

Additional well-being and health funding to support student hardship 2024/25 (£2m, universities and further education providers of higher education)

25. We strongly encourage universities and colleges, working with their Students’ Unions or equivalent body, to build on measures to address the ongoing cost of living increases impacting on well-being and health, including mental and physical health. All students, including postgraduate and international students should be considered for support, subject to need.

26. Universities and colleges must ensure that student financial support is informed by equality impact assessments.

27. Financial support may include:
i). increasing and/or extending the availability of, and criteria for, ‘hardship’ or other financial support to students most in need;
ii). ensuring vulnerable potential applicants and students are supported with information, advice and funding, as appropriate, including those with care-experience backgrounds, carers, those experiencing violence, domestic abuse, sexual violence, and asylum seekers and refugees; 
iii). ensuring that potential applicants and students with protected characteristics, including those from lower socio-economic backgrounds, are aware of all financial support, information and advice available and relevant to them;
iv). ensuring all financial information, advice and services are available and accessible in Welsh; 
v). involving students with experience of financial challenges in developing and reviewing financial support services;
vi). providing inclusive activities, resources, services and/or products at low or no-cost to support potential applicants and students experiencing financial pressures, including where this may impact on well-being, health, mental health, a sense of belonging or loneliness, the student experience, retention and success.

28. While ‘one-off’ support and activities may primarily benefit current students, some provision could support well-being, health and mental health provision in the longer-term. Longer-term sustainability might include providing web-based information and resources.

Universities should use this funding to:
* provide financial support to higher education students, by extending funding or other resources for those experiencing financial pressures, which are impacting on their student experience, well-being, health, retention and success;
* review, and promote on websites, baseline services to support applicants’ and students’ well-being and health, including mental health;
* work with unions to support the mental health and well-being of staff, including as they provide effective support to students as part of a whole-institution approach to well-being and health;
* promote and provide accessible staff training on mental health; and
* provide mental health training in Welsh for staff and students.

Directly-funded colleges should use this funding to:
* enhance and promote money advice and information services for higher education students;
* provide financial support to higher education students by extending hardship funding or other resources to support those experiencing financial pressures;
* support potential applicants and applicants transitioning into higher education provision, as well as existing students;
* measures to help address the cost of living increases on higher education students of all ages and those transitioning into higher education;
* extend, enhance or subsidise period dignity and personal hygiene products and/or clothes washing services for students;
* working collaboratively with Students’ Unions or the equivalent to ensure support provided meets the needs of higher education students; and
* involve students with experience of financial challenges in reviewing the support provided.

University and directly funded college funding allocations

Universities

29. The 2024/25 Well-being and health, including mental health, strategy implementation plan funding will be allocated in one payment, on the basis of student headcounts, as set out in Annex A.

30. The 2024/25 additional well-being and health funding to support student hardship funding will be allocated in one payment, on the basis of student headcounts, as set out in Annex B.

31. In 2024/25 we will allocate both Annex A and Annex B funding in one tranche payment in December 2024 subject to:
i). submission of 2023/24 well-being and health including mental health monitoring reports including confirmation of the satisfactory use of 2023/24 funding.

32. Submission of 2024/25 Well-being and health, including mental health, implementation plans (see template provided at Annex C and Appendix C1). The submission date for this reporting is Friday 31 January 2025.

33. We expect universities to manage and spend in full in-year their 2024/25 allocations.

34. We will reclaim any uncommitted underspend at the end of 2024/25, unless there are exceptional circumstances, and we will reclaim/withhold future funding where there is unsatisfactory or limited reporting against our monitoring requirements.

Directly-funded colleges

35. The 2024/25 additional well-being and health funding to support student hardship funding will be allocated in one payment, on the basis of student headcounts, as set out in Annex B.

36. In 2024/25 we will allocate Annex B funding in one tranche payment in December 2024 subject to:
* submission of 2023/24 additional well-being and health funding to support student hardship health monitoring reports including confirmation of the satisfactory use of 2023/24 funding.

37. 2024/25 Additional well-being and health funding to support student hardship implementation plan (see template provided at Annex D). The submission date for this reporting is Friday 31 of January 2025.

38. We expect directly funded colleges to manage and spend in full in-year their 2024/25 allocations.

39. We will reclaim any uncommitted underspend at the end of 2024/25, unless there are exceptional circumstances, and we will reclaim/withhold future funding where there is unsatisfactory or limited reporting against our monitoring requirements.

University and directly funded college monitoring requirements

40. We will monitor expenditure and the use of this funding. Our monitoring may be used to inform our reporting to the Welsh Government or to share interesting practice.

University monitoring

41. We are combining the monitoring of the £2m annual strategy implementation funding with monitoring of the additional £2m for hardship. The universities’ combined monitoring template for both allocations is provided in Annex E and Appendix E1 of this publication. (See timetable below for submission dates.)

42. Combined monitoring is intended to ease the burden of reporting against well-being and health allocations and it recognises that the universities’ implementation plans will drive the planning and use of the funding in the round.

Directly-funded college monitoring

43. For colleges a monitoring and case study template is attached as Annex F and Appendix F1. (See timetable below for submission dates.)

Timetable

44. Table 1 below sets out the universities and directly funded college submission and reporting deadlines.

Table 1

Submission and reporting requirements	Submission date
Universities completed 202425 Well-being and health, including mental health, implementation plan	Friday 31 January 2025
Directly funded colleges completed 2024/25 additional well-being and health funding to support student hardship implementation plan	Friday 31 January 2025
Universities and directly funded colleges completed 2024/25 monitoring report template	Friday 26 September 2025

Further information / responses to

45. For further information contact Ryan Stokes ([email protected]).

46. Responses to be submitted to Ryan Stokes ([email protected]).

Assessing the impact of our policies

47. We have updated our ongoing impact assessment to take account of equality, diversity and inclusion. We also considered the impact of policies on the Welsh language, and Welsh language provision within the HE sector in Wales and potential impacts towards the goals set out in the Well-Being of Future Generations (Wales) Act 2015 including our Well-Being Objectives.

48. Our impact assessment findings include:
* identifying likely positive impacts on the following protected characteristics: age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. No negative impacts were identified.
* confirming that the funding supports five of the seven well-being goals and takes account of the five ways of working.
* noting that the funding guidance and monitoring seeks to have a positive impact on the Welsh Language.

Spin-outs Review Implementation: Best practices adoption list

This is a list of UK higher education providers that have voluntarily adopted the best practice policies for spin-out deal terms as highlighted in the November 2023 Independent Review of Spin-outs.

This list has been compiled by the Department for the Economy Northern Ireland, Medr, Research England and the Scottish Funding Council, based on information submitted by institutions.

This joint list will be updated periodically; the below includes higher education providers who have confirmed adoption by 1 November 2024.

Wales

Institution / Link to adoption statement/policies
Cardiff University
Swansea University

England

Institution / Link to adoption statement/policies
Brunel University London
Cranfield University
De Montfort University
Durham University
Imperial College London
Institute of Cancer Research
Keele University
King’s College London
Lancaster University
London School of Economics and Political Science
Loughborough University
Manchester Metropolitan University
Newcastle University
Northumbria University
Nottingham Trent University
Open University
Oxford Brookes University
Queen Mary, University of London
Royal Holloway, University of London
Royal Northern College of Music
Sunderland University
University College London
University of Bedfordshire
University of Birmingham
University of Bristol
University of Cambridge
University of Central Lancashire
University of Exeter
University of Kent
University of Lincoln
University of Liverpool
University of Manchester
University of Nottingham
University of Oxford
University of Reading
University of Salford
University of Sheffield
University of Southampton
University of Sussex
University of the Arts London
University of the West of England
University of Warwick
University of Westminster
University of York

Scotland

Institution / Link to adoption statement/policies
University of Aberdeen
University of Edinburgh
University of Glasgow

Purpose

1. This paper outlines proposed changes to how course (activity) transfers are treated in the achievement measures, and seeks feedback.

2. The aim is to implement the changes for the 2023/24 performance cycle.

Background

3. In 2022/23, a system for handling programme level transfers was implemented, after a consultation. We said we would then implement a method for course transfers using similar rules in 2023/24.

4. In previous cycles, a course that was transferred is treated as a withdrawal in the measures. We aim to treat transfers as a neutral outcome (excluded from the measures) if the transfer meets a set of conditions.

Proposed rules (see Annex A flow diagram)

5. A course transfer would be treated as a neutral outcome if:
* The course is listed as a transfer (LA31 = ‘4’)
* And the learner has another course which did not end in a transfer:
a). At the same provider
b). Which began after the last activity ended
(i), Or within 7 days before the end, as long as that is still after the start date
c). In the same academic year
(i), Or was an activity with the same reference code (LA06) in the following academic year
d). Which started within 21 days after the original activity ended
Or within 126 days (18 weeks) if the transfer was to the same reference code in the following academic year
e). Which was the same level or higher
(i), Unless the transfer happened within the first 8 weeks of the original activity
(ii), A2 to AS transfers are not allowed
(iii), Qualification levels are based on the Qualifications in Wales dataset if available, LA22 if not. If the new activity doesn’t have a defined level, the old activity must also not have a defined level
(iv), For multi-level courses, the most generous interpretation is taken (lowest level for the original activity, the highest level for the new activity)
And if the original activity was assessable, the new activity must also be assessable
(v), Unless the transfer happened within the first 8 week of the original activity
f). And if the original activity was a “main” activity (LA47 = ‘05’) the new activity must also be a main activity.
(i), Unless the transfer happened within the first 8 week of the original activity
g). And if the original activity was a non-generic activity (LA06 does not begin with ‘L’) the new activity must also be non-generic
h). Only one activity may be transferred to this new activity

6. If a learner transfers programme, all the courses listed as transfers within that programme are treated as neutral outcomes, whether or not they meet the above conditions. The programme transfer must meet the rules for programme transfers.

7. If an A level course was transferred in the second year, it is only a neutral outcome for the 2-year measures (A2 completion and grade outcomes). It would count as a non-continuation from AS to A2.

8. Course transfers would also be treated as neutral in the success rate calculation for the vocational programme measures if they meet the above rules. Previously all course transfers were treated as neutral in the programme success rate.

9. If a learner has been recorded as taking the same activity multiple times in a year at a provider, the activity with the latest end date will be taken. The earlier versions of the activity will be removed from the measures, whether or not they were listed as transfers.

10. Course transfers that are treated as neutral outcomes will be monitored, in the same way as programme transfers.

Impact of changes

11. The impact of these changes was calculated for the 2022/23 measures. These were calculated to illustrate impact. For speed they were calculated using college data.

Table 1a: Effect of new transfer method on FE vocational course measures, 2022/23

Transfer method	Early dropout rate	Completion rate	Pass rate
Original	9%	88%	75%
New	7%	88%	76%

Table 1b: Effect of new transfer method on FE A level course measures, 2022/23

Transfer method	Early dropout rate	AS completion rate	Retention rate	A2 completion rate
Original	13%	84%	73%	92%
New	10%	84%	73%	93%

Transfer method	A*	A* to A	A* to B	A* to C	A* to D	A* to E
Original	8%	24%	48%	70%	83%	89%
New	8%	25%	48%	70%	84%	90%

Table 1c: Effect of new transfer method on FE vocational programme measures, 2022/23

Transfer method	Early dropout rate	Completion rate	Success rate
Original	11%	86%	78%
New	11%	86%	78%

12. In the cases where a transferred activity did not meet the rules, we recorded the reason [Table 2].

13. Please note, aside from “no course found” this is probably an overcount of these reasons.

Table 2: Reason why potential transfer target was rejected for activity transfers that couldn’t be validated, FE measures, 2022/23
Note [c]: Values under 5 suppressed to protect confidentiality.

Measure type	No course found to transfer to	Transfer did not take place within 21 days	Same course in the following year: did not take place within 126 days	Activity started before transferred activity ended	Transfer from non generic qual to generic qual	This activity was already used to validate a different transfer
Vocational course	1,110	2,540	280	570	450	180
Vocational programme	295	980	0	310	140	80
A level	0	5	[c]	10	[c]	0

Measure type	Transfer not to same level or higher	Transfer from main/core category to non-main/core category	Transfer not to same or higher level of assessability	Transfer was to another academic year	All
Vocational course	85	30	10	[c]	5,265
Vocational programme	40	15	5	0	1,890
A level	5	0	0	0	25

Consultation questions

14. Considering the above proposals:

Q1	Should transfers to an activity with a different reference number in the following academic year be accepted? (Provided the transfer took place within 21 days of the original activity ending)
Q2	Transfers to the same course in in the following academic year are allowed to enable the recording of 1.5+ year courses in two-year programmes. The rule that these transfers must take place within 18 weeks is to allow for a summer break. Is the 18-week time period the right length?
Q3	Are there occasions when a new activity might start before the old activity has ended? Is a 7-day grace period long enough for this?
Q4	Are there times when a learner might reasonably transfer from an assessable activity to a non-assessable activity?
Q5	Are there times when a learner might reasonably transfer from a main activity to a non-main activity?
Q6	Are there times when a learner might reasonably transfer from a non-generic activity to a generic activity?
Q7	Are there occasions when a learner might transfer from multiple activities to a single activity?
Q8	How should valid transfers in the second year of an A level course be treated?
Q9	Do you have any other thoughts about the proposed rules?

Responses and next steps

15. We are asking for responses to this consultation by 29 November 2024, to be sent to [email protected].

16. Once we receive responses we will consider them further and send out final guidance by December.

Further information

17. Any queries should be sent to [email protected].

Introduction

1. This publication provides information and requests updates from universities on their actions to tackle violence against women, domestic abuse, and sexual violence (VAWDASV) in higher education, including as such behaviours relate to people regardless of how they identify.

2. Though this publication is primarily intended for universities, other tertiary education providers may find it useful in reviewing their own work on VAWDASV and identity-based violence, harassment and abuse.

3. This is Medr’s first publication on VAWDASV. This publication should be read in conjunction with HEFCW circulars W20/39HE: Tackling violence against women, domestic abuse and sexual violence in HE published in November 2020, and W23/29HE: Tackling violence against women, domestic abuse and sexual violence in higher education, published in November 2023.

4. Our impact assessments informing the above circulars have shown women are more likely to experience domestic abuse and sexual violence, therefore, we have framed this information in terms of VAWDASV. There will be practice and learning that will inform actions to tackle violence, abuse, and harassment regardless of how a person expresses their identity, and this information takes account of this.

5. In February 2024, HEFCW provided universities with feedback on the information they provided in response to circular W23/29HE. In this publication, we are continuing our focus on safe and inclusive higher education, seeking assurance of universities’ progress towards addressing feedback from previous submissions and their continued work towards strengthening related policies and procedures in 2024/25.

6. At the time of writing, Medr is consulting on its first Strategic Plan. The proposed plan outlines Medr’s high-level vision for the Welsh tertiary education system, as well as highlighting eight long-term ambitions, two of which are a ‘greater focus on learner engagement and wellbeing’, and ‘better learner outcomes and improved learner experiences’. The proposed plan additionally highlights Medr’s five strategic aims, the first of which is ‘to focus the tertiary sector around the needs of the learner – their experience, achievement and well-being, ensuring they are involved in decision-making and encouraging participation in learning at all stages in life.’ Medr’s Strategic Plan will be presented to Welsh Government on 15 December 2024.

Medr’s duties and responsibilities

7. Medr, the Commission for Tertiary Education and Research, became operational on 1 August 2024 after the closure of the Higher Education Funding Council for Wales (HEFCW) on 31 July 2024.

8. There are specific duties on public sector organisations in Wales, including Medr, under the Public Sector Equality Duty (Wales).  Medr has a duty to promote equality of opportunity, as well as to:
i). identify and collect relevant information about equality;
ii). revise and publish outcome focused equality objectives;
iii). identify and collect information about differences in pay;
iv). train staff and collect employment information;
v). revise and publish a strategic equality plan;
vi). involve people who represent one or more of the protected groups and who have an interest in the way Medr carries out its functions;
vii). consider the general duty in procurement processes;
viii). produce an annual report each year; and
ix). publish accessible documentation.

9. Medr has a strategic duty to promote equality of opportunity in tertiary education and will introduce a staff and student/learner well-being related condition of registration. Paragraph 3.142 of the Tertiary Education and Research (Wales) Bill: Exploratory Memorandum notes: “The initial and ongoing conditions regarding support for and the promotion of student and staff welfare will introduce new regulatory requirements for providers which, it was envisaged, would encompass matters such as mental health, wellbeing and safety of learners and staff at the provider. The Commission will be required to set out and publish requirements which must be met by registered providers regarding their arrangements in respect to the initial and ongoing conditions. In the context of student and staff welfare, it is envisaged that ‘arrangements’ would include policies, procedures and support services for student and staff wellbeing and safety. ‘Wellbeing’ in this context is intended to mean emotional wellbeing and mental health. ‘Safety’ is intended to mean freedom from harms including harassment, misconduct, violence (including sexual violence), and hate crime.” We will consult on the new registration process.

10. The Violence against Women, Domestic Abuse and Sexual Violence (Wales) Act 2015 outlines a duty on Medr (‘the Commission’) to “issue guidance to governing bodies of institutions in Wales within the higher education sector on how the bodies may contribute to the pursuit of the purpose of [the] act.” As Medr develops its functions and regulatory tools, we will provide further information.

11. Preventative approaches to tackling VAWDASV contribute to the ways of working outlined within the Well-Being of Future Generations (Wales) Act 2015, and are supported and informed by relevant legislation and Welsh Government priorities including Welsh Government’s VAWDASV Strategy 2022-2026, and by the Equality Act 2010.

Background and context

12. This publication and request for information:
takes account of Welsh Government’s 2022-26 VAWDASV strategy and blueprint;
* contributes to higher education providers’ ongoing strategic equality duties, and monitors progress against objectives within institutional (including Strategic Equality Plans) and national strategies;
* is informed by the Universities UK’s six publications^[1] in the Changing the Culture series; and
* takes account of Estyn’s report on peer-on-peer sexual harassment among 16–18-year-old learners in further education.

13. In 2015, Public Health England published ‘Strategy for Addressing Sexual and Domestic Violence in Universities: Prevention and Response’, developed as part of a Welsh Government funded bystander programme. The resource summarises strategic approaches to tackle VAWDASV, with a particular emphasis on student- and learner-informed aspects of work.

14. In 2016, the United Nations organisation, UN Women, published a blueprint for addressing campus violence. This highlights four key principles^[2] to create a safe living and learning environment on campus, and ensure that survivors receive the right support whilst perpetrators are held to account for their actions. The ten ‘essentials’ for addressing campus violence cover institutional environment, services offered, and prevention of VAWDASV.

15. In 2018, UN Women further published a guidance note relating to on-campus violence prevention and response. This produced a series of ten recommendations for institutions, encouraging universities to:
i). assess the situation;
ii). put a policy in place;
iii). assign a dedicated university coordinator to address violence against women;
iv). put in place protocols that outline the procedures;
v). consider interim and supportive measures;
vi). consider monitoring and evaluation mechanisms;
vii). have a dedicated budget;
viii). consider provision of essential services;
ix). consider awareness raising and bystander programmes; and
x). promote respectful relationships and challenge harmful masculinities.

16. The above reports remain relevant, despite their publication dates. The UN Women report makes several references to the importance of staff and student awareness raising, and bystander intervention training. A report, ‘Findings from a National Study to Investigate How British Universities are Challenging Sexual Violence and Harassment on Campus’ (Donovan, Bracewell, Chantler and Fenton), published in 2020, highlights the challenges of voluntary training provision, including the student gender bias often identified in those attending; “A key concern about prevention activities remaining voluntary is the gender bias identified by respondents in those who attend, i.e. that it is female students in certain areas who are more likely to attend.” As a result of this, providers should consider the appropriateness of mandatory or voluntary training against transparent criteria, and review the diversity of attendees to ensure it is promoted to, and engages, the full diversity of the staff and student population.

17. In July 2022, ACE Hub Wales and Traumatic Stress Wales published the Trauma Informed Wales Framework, outlining a ‘societal approach to understanding, preventing and supporting the impacts of trauma and adversity’. The framework’s target audience is those responsible for making trauma-informed policy and developing trauma-informed organisations and services and, therefore, it is relevant to tertiary education. Trauma-informed approaches to higher education were explored more recently in a blog by the Higher Education Policy Institute (HEPI).  Universities have identified trauma-informed practice as a key area for further development and information. Medr will collect and share practice, gather resources to be shared and publish information for the tertiary sector to support enhanced practice.

18. Welsh Government’s ‘Sound’ initiative, launched in 2023, encourages men aged 18-34 in Wales to consider issues related to gender-based violence, through discussion with peers, the provision of trusted advice, and becoming active bystanders in their peer groups. The webpages, Instagram, TikTok and YouTube, provide sound bites of content for young people, with a view to change the culture and promote healthy relationships, consent, and identify ingrained behaviours that are unhealthy. This, and other resources included in Annex B of W23/29HE, may be useful to education providers in ongoing conversations about VAWDASV with a wider audience.

19. Of universities’ Strategic Equality Plans covering 2024 to 2028, seven make direct reference to VAWDASV, gender-based violence, or sexual misconduct. VAWDASV has implications for well-being and health, including the mental health of staff and students. It has further implications for intersectionality and trauma informed considerations, as well as anti-racism, including Nation of Sanctuary and University of Sanctuary commitments.

20. Medr is a member of the Welsh Government’s VAWDASV blueprint work stream on public spaces^[3]. We continue to work with Welsh Government and other partners to inform our understanding of this policy area following our transition into Medr, and as we operate within a tertiary context.

What has changed since HEFCW’s last circular?

21. Since the last information issued by HEFCW, new reports and resources have been published. This publication takes account of these, including as they respond to the lasting impact of the COVID-19 pandemic on staff and students. We encourage universities to take account of their findings, recommendations, and practice. A list of further resources can be found in Annex B of HEFCW circular W23/29HE.

22. In January 2024, the Welsh Government published its action plan on peer-on-peer sexual harassment in education settings. The plan takes account of the Everyone’s Invited platform findings, the Senedd Children, Young People and Education (CYPE) committee inquiry into peer-on-peer sexual harassment among learners, and Estyn’s thematic report on peer-on-peer sexual harassment among 16 to 18-year-old learners in further education. The action plan sets out seven priority areas for action, which are:
i). prevention;
ii). early intervention;
iii). learner support and wellbeing;
iv). professional learning and leadership;
v). parents, carers, and the community;
vi). addressing sexual harassment in the online context; and
vii). research and evaluation.

23. Whilst this action plan is for schools and colleges, many elements of it can inform practice and processes within higher education and could be used as a baseline against which to assess provision. Medr will provide new opportunities to share relevant learning across different strands of the tertiary education system, as was requested by universities in responses to W23/29HE.

24. In January 2024, the Senedd’s Equality and Social Justice Committee published ‘How we must all play our part: a public health approach to halting the epidemic in gender-based violence’. Action 5 of the report, in relation to higher education, states that Medr should ‘work with universities to agree actions which strengthen preventative approaches across the sector’. The report further highlights the need to apply consideration to migrant people with experience of VAWDASV, particularly those with no recourse to public funds (NRPF), which includes many international students.

25. In April 2024, the 1752 Group, a research and campaign organisation working to address staff sexual misconduct in higher education, published ‘Self-Assessment and Strategic Planning Tool: Sexual Violence, Harassment & Misconduct (SVHM) in Higher Education’, designed to support higher education institutions to reflect on progress, identify further targets, and map deliverables in this area. This and other toolkits, including ‘#CombatMisconduct’, published in 2021, by AVA (Against Violence & Abuse), National Union of Students UK and Universities UK, may be used in supporting universities to make progress against objectives laid out in Strategic Equality Plans and they will be of interest to other higher education providers.

26. In June 2024, Welsh Government’s National Advisers on VAWDASV published an action plan for 2024 to 2025, outlining the actions that will be taken to prevent violence and to support and protect people who have experienced violence. In line with Welsh Government’s VAWDASV Strategy 2022-2026, the high-level aim is ‘to work with all stakeholders in Wales to improve understanding of and response to presentations of VAWDASV within their services and to enhance the pathways of support for survivors in a collaborative whole system approach’.

27. In September 2024, Wales Without Violence published their Engaging Men and Boys In Violence Prevention toolkit, containing research reports and infographics to support organisations in engaging men and boys in violence prevention. This includes a report on key findings from ‘Test and Learn’ projects across Wales, and a Wales-wide review of programmes.

28. The new Worker Protection (Amendment of Equality Act 2010) Act 2023 came in to force on 26 October 2024. This introduces a positive legal obligation on employers to take reasonable steps to protect their workers from sexual harassment. The Equality and Human Rights Commission (EHRC) has updated its previous guidance to include information on the new preventative duty so that employers understand their obligations under equality law.

Reviewing progress and tackling violence against women, abuse and sexual violence in higher education and sharing practice

29. Universities identified several areas where they would welcome further VAWDASV information. We have taken note of these, and will consider further how we can best respond to them, including by taking a tertiary ‘whole sector’ approach.

30. In line with the Equality and Social Justice Committee’s expectations for Medr to work with providers to strengthen preventative approaches, and the National Coordinators’ commitment to improving awareness and responses to VAWDASV in Wales, we are asking universities to provide us with information as part of our ongoing monitoring and assurance processes. This information will inform our understanding of the level of ambition and pace, and the progress being made in tackling VAWDASV and gender-based violence, abuse, and harassment in higher education. We will use this information to:
i). inform our understanding of universities’ priorities for the academic year 2024/25, particularly where this relates to the feedback previously provided by HEFCW;
ii). evidence progress towards securing safe and inclusive higher education;
iii). share interesting practice;
iv). report to Welsh Government on higher education’s contribution to the Violence Against Women strategy and blueprint; and
v). inform our policy and registration developments.

31. We set out our reporting requirements at Annex A.

32. If there is specific information you will provide to us that you wish us not to share more widely, please let us know. Please only provide information about services or activities and not individual cases.

Timetable

33. Please send your responses to Orla Tarn ([email protected]) by Friday 7 March 2025.

Assessing the impact of our policies

34. We have carried out an impact assessment screening to help safeguard against discrimination and promote equality. We anticipate a positive impact on sex, age, disability, gender reassignment, race, religion, sexual orientation and marriage and civil partnership. We have assessed the impacts on socio-economic characteristics and anticipate a positive impact on communities of interest^[4] and communities of place^[5].

35. We have considered the impact of policies on the Welsh language, and Welsh language provision in higher education and potential contribution to the goals set out in the Well-Being of Future Generations (Wales) Act 2015. Contact [email protected] for more information about impact assessments.

Further information

36. For further information, contact Orla Tarn ([email protected]).

Footnotes

^[1] Changing the culture 2016; Changing the culture: directory of case studies 2017; Changing the culture: one year on 2018; Changing the culture: two years on 2019; Changing the culture: tackling staff-to-student sexual misconduct 2022;Changing the culture: sharing personal data in harassment cases 2022.

^[2] The four principles outlined are a comprehensive approach, a survivor-centred approach, a human rights-based approach and an approach that centres accountability.

^[3] Welsh Government’s blueprint is being informed by six work streams: sustainable whole approach system; needs of children and young people; needs of older people; tackling perpetration; work place harassment; gender based harassment in public spaces.

^[4] Communities of interest are those who share an identity, e.g. lone parents, carers; those who share one or more protected characteristic, e.g. LGBTQ+, older people; groups of people who have shared an experience, e.g. homelessness, the same local health/social care system or local service.

^[5] Communities of place are those who share a geographical location, e.g. Wales Index of Multiple Deprivation (WIMD).

Introduction

1. This publication sets out the arrangements for the National Student Survey (NSS) 2025 and the action required from all participating universities, colleges and other higher education providers by 29 November 2024. Providers are asked to:
– provide up-to-date contact details
– complete the ‘my survey options’ form
– submit NSS 2025 sample templates with contact details of eligible students.

Note that the six new Welsh subscribers to HESA, that have specifically designated higher education course provision and are submitting student record data for the first time for 2023/24, are not required to participate in the NSS 2025. We will be in contact with these six providers about future implementation of the NSS for them.

2. This publication also provides an overview of the administration of the survey, provider support contact details, survey timetable and dissemination of results.

Background

3. The NSS is a UK-wide survey undertaken by final year, undergraduate higher education students to give feedback on their course. It is managed by the Office for Students (OfS) on behalf of the UK funding and regulatory bodies – the Department for the Economy (Northern Ireland), the Scottish Funding Council and Medr (the Commission for Tertiary Education and Research in Wales). The survey provides information for prospective students to help them find the right course for them. It also provides valuable information for institutions, stakeholders and policymakers.

4. The survey will be delivered on behalf of the UK funding and regulatory bodies by:
– Ipsos, which will administer the survey.
– CACI Limited, which will deliver the data dissemination portal for providers.

5. The survey is a key component of the quality assurance and wider regulatory landscape in UK higher education. Participation is compulsory for higher education providers as follows:
– In Wales, providers that are regulated or funded by Medr for higher education provision are expected to participate in the NSS to ensure that the views of their diverse student populations are represented, in line with their duties to advance equality of opportunities, eliminate unlawful discrimination, foster good relations and promote equality. NSS outcomes will provide information to Medr, the regulator for tertiary education in Wales.
– In England, all providers registered with and regulated by the OfS will be expected to participate in the NSS as an ongoing condition of registration.
– In Northern Ireland, NSS participation is a condition of funding as set out in the financial memoranda between universities and the Department for the Economy (Northern Ireland). Further education colleges in Northern Ireland take part in the NSS to meet quality assurance requirements.
– In Scotland, participation is a condition of the Scottish Funding Council’s funding for higher education providers.

6. The OfS has confirmed that providers in England are not required to promote the 2025 survey to their students. Providers in Wales, Scotland and Northern Ireland are still required to promote the survey. We expect providers to review any internal campaigns, to ensure that they meet the guidance on marketing and promoting of the NSS and avoiding inappropriate influence (see the 2025 good practice guide).

7. During survey fieldwork responses will be monitored, and targeted follow-up will be carried out to ensure that publication thresholds are met. In early March, in addition to the targeted follow-up, all providers that are at risk of not meeting the publication threshold will be put into the booster phase to send additional email reminders and an additional SMS to their non-responding students. The booster phase will start automatically if a provider’s response rate is below 43 per cent by mid-March, and will continue for some until mid-April. The fieldwork timetable is set out in the Ipsos setup guide for providers which is available on the Ipsos NSS extranet.

The 2025 survey

8. For 2025, the NSS questionnaire will be the same as the NSS 2024. The survey will be delivered across England, Wales, Northern Ireland and Scotland. The freedom of expression question will be asked to students who study in England only and the overall satisfaction question will be asked to students in Scotland, Wales and Northern Ireland only.

9. The full list of NSS 2025 questions and response scales can be found on the OfS website.

10. The optional bank questions and their response scales will remain the same in 2025 using the Likert response scale.

11. Ipsos administers the survey on behalf of the UK funding and regulatory bodies. It is responsible for contacting students, promoting the survey and providing cleaned data to the UK funding and regulatory bodies.

12. As part of its role, Ipsos will liaise directly with providers regarding survey administration and will support the running of the survey by:
– offering guidance on the specifics of the survey programme, such as start week, selecting optional questions and provider-specific questions
– for providers promoting the survey
–* supplying NSS-branded marketing materials and advising providers on the production of their own materials.
–* facilitating provider incentive schemes to encourage students to take part in the survey.

13. Further information about marketing and promoting the survey will be provided in the good practice guide from Ipsos on 23 October 2024.

14. Providers will be invited to select one of five weeks when Ipsos can launch the survey to their students. There will be no communication from Ipsos with students outside of the times agreed with individual providers.

15. The survey timetable will run as follows:
i. The NSS will launch on 8 January 2025;
ii. The survey fieldwork will take place between 9 January and 30 April 2025 and will be run by Ipsos;
iii. The UK funding and regulatory bodies will issue a publication in spring 2025 detailing the plans for NSS 2025 results publication;
iv. A provisional date for publication of the NSS results on the OfS website is 9 July 2025 at 09:30am;
v. Detailed results will be supplied to individual providers through the new dissemination portal provided by CACI Limited on the same date and time;
vi. NSS results at course level will be published on the Discover Uni website.

16. Ipsos has issued a comprehensive guidance document, ‘Setting up and preparing for the National Student Survey 2025’, for all participating providers on 23 October 2024. The guidance should be read in conjunction with this publication.

17. For NSS 2025, CACI Limited will provide the survey results on a newly developed data dissemination portal on behalf of the UK funding and regulatory bodies. The results portal allows providers to access additional, unpublished elements of their data, including open text comments, data from the additional bank of questions and provider-specific questions, and data below the publication threshold.

18. The new NSS data dissemination portal will launch in December 2024. However, Texuna Technologies will continue to provide a dedicated NSS service desk support providers in accessing their data and responding to queries while the new portal is being developed. Guidance for providers about downloading historical data from the current NSS data dissemination portal will follow in due course.

19. For NSS 2025, CACI Limited will provide the survey results on the newly developed data dissemination portal on behalf of the UK funding and regulatory bodies. In preparation for dissemination of NSS 2025 results, CACI Limited will contact providers in spring 2025 to confirm user login details and confirm the details of publication of NSS 2025 results on the portal.

Discover Uni website

20. The Discover Uni website is a resource for prospective undergraduate students looking for information about undergraduate courses in the UK. It is managed by OfS on behalf of the UK funding and regulatory bodies. The NSS outcomes are published on the Discover Uni website annually. The current publication threshold for NSS results is a 50 per cent response rate and with at least 10 students responding.

21. The website also contains data taken from the HESA Graduate Outcomes survey, and the HESA Discover Uni return (formerly known as the Unistats return), which collects data about courses. More information about the HESA Discover Uni return is provided below.

HESA Discover Uni return 2024

22. All providers in Wales that subscribe to HESA make a Discover Uni data return to HESA to enable data about their courses to be included on the Discover Uni website. All providers regulated or directly funded by Medr for HE provision and providers with specifically designated HE course provision in Wales are required to submit this information to HESA for their provision.

Actions for providers

23. All higher education institutions and further education colleges in Wales that are regulated and/or funded for higher education provision should:
a). review and (where necessary) update their relevant NSS provider contact details by 29 November 2024. The information should be supplied using the ‘My details’ form on the NSS extranet. Ipsos issued login details for the NSS extranet to the nominated main and secondary NSS provider contacts in the week commencing 30 September 2024.
b). submit their completed ‘My survey options’ form by 29 November  2024 through the NSS extranet. This form asks for providers’ preferences on their survey start week, optional questions and details of any prize draws.
c). populate their NSS 2025 sample templates with the requested contact details for all students on their target list; this is a list of all students eligible for NSS 2025, based on the student data submitted to the 2023/24 HESA student record. Details should be supplied by 29 November 2024 via the ‘Upload sample data’ section of the NSS extranet. Any proposed additions to or removals from the target list should follow the process set out by Ipsos.

24. Instructions on how to supply this information are included in the NSS 2025 setup guide, which will be issued to provider contacts by Ipsos on 23 October 2024 and is also available on the NSS extranet. The guidance includes information regarding survey administration, key responsibilities and dates.

25. All providers are reminded to ensure that the course mapping to the relevant Common Aggregation Hierarchy (CAH) is correct. Providers should consider the resultant mapping to the CAH3 code in terms of the information that prospective students can access to inform decisions about studying higher education. Subject areas such as Nursing, Economics, and Finance may be areas that providers should review to confirm they are coded in the appropriate CAH3 subject.

26. Detailed guidance relating to NSS 2025 and the actions requested from higher education institutions and further education colleges in Wales who are returning student data to HESA and are participating in the NSS can be found at Annex A.

27. A summary of required action to be taken by participating providers is provided in Table 1 below.

Table 1: Provider actions and key milestones

Date	Actions
23 October 2024	Ipsos to issue NSS 2025 setup guide and good practice guide to providers.
29 November 2024	Review and update NSS contact details.
29 November 2024	Complete ‘my survey options’ form.
29 November 2024	Submit NSS 2025 sample templates with contact details of eligible students.
9 July 2025	Provisional date for publishing the NSS 2025 results on the OfS website and for dissemination of detailed results to individual providers through the NSS data dissemination portal.

Inappropriate influence on the survey

28. To maintain the integrity of the NSS data, it is important to ensure that students who complete the survey have not been influenced by their provider, or any other parties, to respond in a way that does not reflect their true opinion. The OfS is responsible for managing the process, on behalf of all the UK funding and regulatory bodies, to address any concerns that students have been inappropriately influenced in their completion of the NSS.

29. The procedures for investigating allegations of inappropriate influence on survey results are intended to be read in conjunction with the good practice guide issued by Ipsos, which explains what constitutes inappropriate influence and how to avoid it when encouraging student participation. We urge providers to ensure that all staff who are responsible for the running of the survey are familiar with Ipsos’s good practice guide, and seek advice where needed from Ipsos or the OfS on their approach to avoiding inappropriate influence. A representative from Medr will be involved in any review of a concern of inappropriate influence involving a Welsh higher education provider.

30. A student guide on inappropriate influence is available to help raise awareness among students of the value of their honest views, what to expect from NSS promotion, what is and is not allowed, and where they should go for help and support if they are concerned about being influenced. Providers are asked to inform students about this guide as part of their pre-launch survey plans. More details on this are provided in the NSS 2025 set-up guide issued by Ipsos.

Costs

31. Medr will cover the costs of the 2025 NSS for higher education providers which it regulates and funds.

Further information

32. The active support of participating providers is crucial to ensuring the survey data is of high quality. We encourage all providers and students’ unions to draw on the resources available and to get in touch if they require additional support:

Ipsos: [email protected]	The running of the survey, including: preparing for and marketing the survey; student target lists; optional questions; incentive schemes.
Texuna Technologies: [email protected]	Providers’ detailed results on the NSS data dissemination portal until 3 January 2025, after which CACI Limited will be taking over queries. The contact information for CACI Limited will be shared with providers in due course.
Office for Students [email protected]	Areas such as NSS policy and development; onward use of results; allegations of inappropriate influence.
Medr [email protected]	Any other queries relating to the operation of the NSS in Wales.

Assessing the impact of our policies

33. OfS has conducted a risk assessment screening. As partners in the OfS managed survey, we work with OfS to ensure that the survey and materials aimed at students are available in both Welsh and English in Wales. We will continue to assess the impact of the NSS on the Welsh language to ensure that students are able to fully participate in the NSS in their language of choice.

Introduction

1. This publication provides guidance to support anti-racism and race equality in higher education, and 2024/25 anti-racism funding allocations, match funding expectations, and monitoring requirements.

2. This guidance and funding has previously been referred to as ‘race equality’, but has been referred to as anti-racism funding since 2022 and the release of Welsh Government’s Anti-Racist Wales Action Plan.

3. This funding was originally provided in HEFCW circular W22/05HE: Consultation on funding to support race equality in higher education, to tackle anti-racism and support culture change in higher education, in line with race, access and success policy developments and the Anti-Racist Wales Action Plan. The initial publication included the conditions of match funding and the expectation that universities achieve a race equality charter award by 2024/25. All universities confirmed to HEFCW their intention to meet this commitment by the end of 2025.

4. This publication should be read together with HEFCW circular W23/06HE: Safe and inclusive higher education: supporting equality and diversity education.

5. HEFCW’s remit letter 2024-25 (paragraph 10), issued ahead of the transition into Medr, commended the work of Wales’s higher education sector in promoting equality of opportunity, including through its work towards the Anti-Racist Wales Action Plan.

6. Welsh Government is committed to an Anti-Racist Wales by 2030. At the time of writing, Welsh Government is refreshing its Anti-Racist Wales Action Plan to ensure progress at pace against overarching targets. There will be revised actions, including for the tertiary sector. We expect universities to take account of these actions as and when they are released.

Medr’s duties and responsibilities

7. Medr became operational on 1 August 2024 following the closure of the Higher Education Funding Council for Wales (HEFCW) on 31 July 2024.

8. Medr has a strategic duty to promote equality of opportunity in tertiary education. Paragraph 3.1 of the Tertiary Education and Research (Wales) Bill (as passed) notes:
“The Commission must promote –
a) the provision of support for students finishing courses of Welsh tertiary education who are members of under-represented groups to continue their tertiary education, find employment or start a business”.
b) increased participation in Welsh tertiary education by persons who are members of under-represented groups;
c) increased participation in the carrying out of research and innovation in Wales by persons who are members of under-represented groups;
d) retention of students who are members of under-represented groups to the end of courses of Welsh tertiary education;
e)reduction of any gaps in attainment in Welsh tertiary education between different groups of students where the differences arise from social, cultural, economic or organisational factors; and

9. The Act subsequently defines ‘under-represented groups’ to be:
a) “In relation to tertiary education, groups that are under-represented in Welsh tertiary education as a result of social, cultural, economic or organisational factors; and |
b) In relation to research and innovation, groups that are under-represented in the carrying out of research and innovation in Wales as a result of social, cultural, economic or organisational factors.”

10. Paragraphs 3.134 and 3.135 of the Tertiary Education and Research (Wales) Bill: Exploratory Memorandum requires Medr to “ensure that the ongoing registration conditions of each registered provider include conditions requiring the delivery of measurable outcomes relating to equality of opportunity.”  Medr will develop and consult on the registration process to supersede the current fee and access plan process operating between 2025/26 and 2026/27.

11. In addition to conditions relating to equality of opportunity, Medr will introduce a staff and student/learner well-being and safety related condition of registration. Paragraph 3.142 of the Tertiary Education and Research (Wales) Bill: Exploratory Memorandum notes: “The initial and ongoing conditions regarding support for and the promotion of student and staff welfare will introduce new regulatory requirements for providers which, it was envisaged, would encompass matters such as mental health, wellbeing and safety of learners and staff at the provider. The Commission will be required to set out and publish requirements which must be met by registered providers regarding their arrangements in respect to the initial and ongoing conditions. In the context of student and staff welfare, it is envisaged that ‘arrangements’ would include policies, procedures and support services for student and staff wellbeing and safety. ‘Wellbeing’ in this context is intended to mean emotional wellbeing and mental health. ‘Safety’ is intended to mean freedom from harms including harassment, misconduct, violence (including sexual violence), and hate crime.”

12. Medr will work with universities and colleges in 2024/25 and take account of the implications of working in a tertiary education context, sharing relevant practice as appropriate. HEFCW was a member of the Further Education Anti-Racist Wales Steering Group prior to its closure, to inform and support the transition to a tertiary education-focused organisation.

13. As Medr develops its policies, we will work with the tertiary education sector and partners to agree priorities, terminology and review data. We may issue supplementary guidance where appropriate as this work takes shape.

The purpose of anti-racism funding

14. This funding is to prevent inequality, tackle racism and support the embedding of anti-racist practice within universities and the wider tertiary education sector, support culture change, and contribute to delivering Welsh Government’s Anti-Racist Wales Action Plan.

15. The funding should contribute to universities achieving a race equality charter mark by July 2025, as outlined in the Anti-Racist Wales Action Plan.

16. While this funding is framed in terms of race and ethnicity, universities should take account of how tackling anti-racism will intersect with race, including, but not limited to identity-based harassment, violence and abuse, wellbeing and mental health, refugees and asylum seekers, and religion and belief.

2024/25 allocations and conditions of funding

17. In 2024/25, funding allocations:
i. are subject to universities committing to match fund allocations (as in 2022/23 and 2023/24);
ii. use HESA 2022/23 student data, which are based on the HESA standard registration population, reduced to a headcount (i.e. if a student has more than one enrolment, they are counted once);
iii. use student data which includes the whole student body: all modes, levels and domiciles;
iv. are based on verified 2022/23 HESA data which has been verified by the university;
v. as is our usual practice, Royal Welsh College of Music and Drama student data is included within University of South Wales data and allocation; and
vi. will be made as one payment in November 2024, subject to receipt of 2023/24 anti-racism monitoring reports.

18. Our expectations for the use of match funding are that:
i. the Medr allocation should not result in any decrease in universities’ existing resourcing of anti-racism developments, including their commitment to achieve a charter;
ii. universities commit additional resource to support anti-racism actions, over and above the Medr £1m total allocation;
iii. where any existing anti-racism activities or services are funded through fee and access plan or other sources, these activities and services may be increased by Medr or university match funding. Where this is the case, the university must make clear in all reporting and anti-racism monitoring how, and to what level, this funding has enhanced activities and services, and this may be subject to audit by us;
iv. the match funding and the Medr allocation leads to an increase in pace, and progress towards, tackling racism to embed anti-racist practices, improving race equality, and the achievement of a charter award; and
v. match funding or Medr funding can be used to meet the costs of relevant membership subscriptions, externally facilitated training or other external expertise.

19. 2024/25 allocations are as follows:

University	2024/25 HEFCW allocation (with £50K floor) £	2024/25 Sector matched funding (no floor) £	2024/25  Total £
University of South Wales	159,031	159,031	318,062
Aberystwyth University	53,590	53,590	107,179
Bangor University	72,491	72,491	144,981
Cardiff University	218,948	218,948	437,896
University of Wales Trinity Saint David	111,507	111,507	223,014
Swansea University	144,028	144,028	288,057
Cardiff Metropolitan University	90,446	90,446	180,891
Wrexham University	51,288	51,288	102,576
The Open University in Wales	98,671	98,671	197,343
Total	1,000,000	1,000,000	2,000,000

Resources and information

20. Universities UK has published two briefings on religion and belief which should inform race equality considerations: Tackling antisemitism: practical guidance for universities (June 2021) and Tackling islamophobia and anti-Muslim hatred: practical guidance for universities (December 2021). These briefings form part of Universities UK’s wider changing the culture series, which sets out evidence and recommendations in response to violence against women, harassment and hate crime affecting university students and staff.

21. In July 2022, the Higher Education Policy Institute (HEPI) published Gypsies, Romas and Travellers: The ethnic minorities most excluded from UK education. The report highlights challenges for Gypsy, Roma and Traveller learners, whilst highlighting best practice that exists across the UK, including the GTRSB^[1] into Higher Education Pledge introduced by Buckinghamshire New University in 2021 which commits signatories to:
i. naming a contact point for Gypsy, Traveller, Roma, Showmen and Boater students and prospective students;
ii. data monitoring of Gypsy, Traveller, Roma, Showmen and Boater students and staff numbers;
iii. building a supportive and welcoming culture for Gypsy, Traveller, Roma, Showmen and Boater students;
iv. outreach and engagement to local Gypsy, Traveller, Roma, Showmen and Boater communities; and
v. inclusion, celebration and commemoration of Gypsy, Traveller, Roma, Showmen and Boater cultures and communities.
^[1] GTRSB is used by Buckinghamshire New University as an acronym for Gypsy, Traveller, Roma, Showmen and Boaters. Medr aims to avoid the use of acronyms to describe people but we recognise their use in some resources included within this publication.

22. Three Welsh universities have been awarded University of Sanctuary status; the initiative recognises and celebrates universities that have undertaken work towards the values and principles of the City of Sanctuary Charter 2022-25, and who embody the City of Sanctuary network principles (through a ‘learn, embed, share’ structure).

23. All Further Education Colleges in Wales are affiliated organisations of the Black^[2] Leadership Group (BLG), which provides a range of training and development opportunities, as well as an Ethnic Representation Index (ERI) used by universities in England, Scotland and some specialist institutions.
^[2] ‘Black Leadership Group uses ‘Black’ as an inclusive definition for people from ethnically diverse backgrounds who share a lived experience of the effects of racism’.

24. In March 2024, Black Leadership Group launched the Higher Education Anti-Racism Toolkit (HEART). It has a ten-point plan to embed anti-racism in higher education systems (including strategy, pedagogy and the student and staff experience).

25. Medr and the Office for Students collaboratively fund Student Space. Student Space publishes dedicated wellbeing advice for, and by, higher education students, and has recently published ‘Life as a Black student’.

26. Medr is continuing to work with Advance HE to support two race equality seminars in 2024/25.

Deliverables and monitoring

27. Monitoring information and deliverables for 2024/25 period should build on 2022/23 anti-racism action plans submitted to HEFCW in October 2023, and updates submitted to us as part of 2023/24 monitoring. A monitoring template for submission has been provided in Annex A. 2024/25 deliverables and monitoring should include:
i. the university’s 2024/25 race equality action plan, including progress and deliverables to July 2025; and
ii. a funding statement to account for the Medr allocation and university match funding.

28. We are additionally seeking assurance that all universities are on track to provide a final submission to Advance HE for a race equality charter award by July 2025, as expected by the Anti-Racist Wales Action Plan. Universities must confirm by 1 November 2024 their timeline for charter mark submission and provide regular updates should delays arise. A template has been provided in Annex B.

29. We recognise that universities’ race equality charter action plans may prove satisfactory accounts for the majority of this funding and provide us with sufficient assurance on management and governance structures, annual milestones, pace, progress made and ambition. Where this is not the case, we will request additional information.

30. Should Welsh Government set new expectations on higher education, or the tertiary sector, during the funding period, we may ask for additional monitoring information.

Monitoring dates and returns for 2023/24 and 2024/25 funding and reporting

31. The 2023/24 monitoring submission date is Friday 18 October 2024. Information about deliverables can be found in HEFCW circular W23/20HE: Supporting anti-racism in higher education: 2023/24 guidance and allocations. Please return completed monitoring (Annex A of W23/20HE) to [email protected].

32. Universities should confirm their timeline for final submission to the Advance HE race equality charter award by Friday 1 November 2024. Please return completed form (Annex B) to [email protected].

33. The 2024/25 monitoring submission date is Friday 17 October 2025. Please return completed monitoring (Annex A) to [email protected] and [email protected].

Assessing the impact of our policies

34. We have carried out an impact assessment screening to help safeguard against discrimination and promote equality. We anticipate a positive impact on race, sex, disability, age, religion and belief. We have assessed the impacts on socio-economic characteristics and anticipate a positive impact on communities of interest^[3] and communities of place^[4].

^[3] Communities of interest are those who share an identity e.g. lone parents, carers; those who share one or more protected characteristic e.g. LGBTQ+, older people; groups of people who have shared an experience e.g. homelessness, the same local health/social care system or local service.
^[4] Communities of place are those who share a geographical location, (e.g. Wales Index of Multiple Deprivation (WIMD)).

35. We also considered the impact of this policy on the Welsh language, and Welsh language provision within the HE sector in Wales and potential impacts towards the goals set out in the Well-Being of Future Generations (Wales) Act 2015. Contact [email protected] for more information about impact assessments.

Further information and submissions

36. For further information and for submission of responses, please correspond with Orla Tarn ([email protected]).

Introduction

1. This publication asks higher education providers (HEPs) to review and comment on the changes proposed for the 2024/25 Higher Education Students Early Statistics (HESES) survey relating to return of data for Medr funded Degree Apprenticeship (DA) programmes.

Background

2. Initially the funding of DAs by HEFCW using Welsh Government ringfenced funding was to be run as a three year pilot, with the potential for it to be rolled into HEFCW mainstream teaching funding in the future, so many of the data capture elements and guidance matched those used in HEFCW teaching funding as outlined in, for example HESES and End of Year Monitoring (EYM). The Welsh Government (WG) funding of the programme was not mainstreamed after this time, but continued on the basis of ringfenced grant funding. HEFCW is now part of the Commission for Tertiary Education and Research (Medr), and so any activity previously carried out by HEFCW will be referred to as Medr and Medr funded in this publication.

3. Degree Apprenticeship specific data was first collected by HEFCW for academic year 2018/19. There are currently three points at which data is collected in the academic year (AY) to assist in funding and monitoring DA programmes. The three data collection elements consisted of (using 2023/24 AY as an example):
– 1) Bids and proposals W23/04HE: Degree apprenticeships in Wales and Proposals for Funding 2023/24 and 2024/25 – HEFCW
– 2) In-year monitoring reports W23/30HE: Degree Apprenticeships 2023/24 and 2024/25 monitoring report – HEFCW
– 3) HESA Information Reporting Interface Service (IRIS) end of year data extracts HESA Information Reporting Interface Service (IRIS) – Medr

4. The bids and proposals collection invites providers to submit proposals for funding of new and continuing degree apprenticeships against published frameworks based on realistic projected recruitment numbers. This data is used to set the DA budget for each provider.

5. The monitoring reports are returned for three reference periods through the academic year.

Reference Period (using 2023/24 as example)

One: 01/08/2023 to 15/11/2023

Two: 16/11/2023 to 31/03/2024

Three: 01/04/2024 to 31/07/2024

6. The dates of the data collection periods were initially set to align with data capture dates expected through the HESA student record collection under Data Futures, collecting data three times a year. Since then, the plans have changed to a potential twice a year collection, and the implementation of the collection of in-year data for the HESA student record is currently on hold. This means that currently only retrospective full academic year data is available, and will be the only HESA student record data available at least in the medium term. The monitoring reports data collected is currently used for monitoring of student enrolments in year in the absence of in-year HESA student data, and to calculate funding, using assumed completed credit values for new starters since 2022/23 and using continuing student numbers for starters prior to 2022/23.

7. The HESA IRIS end year extracts for DA programmes are processed through the HESA IRIS system along with other funding extracts such as EYM, premium and per capita. This retrospective, full academic year data is used for monitoring DAs and to calculate any adjustment to funding and clawback against funding.

Issues to consider

8. Through the collection of three sets of data, it can mean up to five data returns during the academic year which is a large burden on providers and also for Medr staff in processing the data.

9. Data is often supplied from different departments within the HEP depending on the data collection, with differing processes and understanding of Medr funding data criteria being applied. As a result there is a risk of differences when trying to compare the different data collected, resulting in extra time spent by Medr staff to decipher issues of consistency and additional time spent by HEPs to help rectify the data.

10. Additionally, looking at recent years’ recruitment patterns and in discussion with HEPs about future plans, recruitment for new starters tends to be concentrated in period 1 for the majority of providers and/or programmes.

Proposed Solution and consultation questions

11. We are proposing to stop the three in-year monitoring data collections carried out by Medr using degree apprenticeship monitoring templates from 2024/25 AY, and instead build early in-year specific degree apprenticeship table(s) into the HESES data collection managed by the Medr higher education statistics team. This would ensure the data would be returned in the same format and using the same data extraction and funding rules as other Medr funded data.

Question 1: Are you supportive of this proposal to replace the three in-year data collections, with one collection through table(s) added to the Medr HESES survey?

12. The proposed HESES table is included in Annex A. We have attempted to keep the structure similar to that previously collected via the monitoring reports, to not increase burden in redesigning the table structure, but still provide the information required for funding and monitoring purposes and to easily compare with HESA IRIS DA data guidance and extractions.

13. In Annex A, HESES Table 4 collects all required data in one table. The use of drop down lists is used to ensure correct information on, e.g. frameworks and pathways, is returned. The table splits the data required into three sections reflecting the data required for the particular funding method applied to starters in the particular AY. Continuing registrations in AY 2024/25 are required for starters prior to 2022/23. Continuing registrations in AY 2024/25 and associated credit values for modules started in 2024/25 are required for starters in 2022/23 and 2023/24 and for new starters in AY 2024/25 to the HESES survey date of 1 November 2024.

Question 2: Are you content with the structure of Annex A Table 4? Do you have any other issues, or comments on the structure of this table or data collected within it?

14. Having this one in-year HESES collection, along with the end year HESA extract of data would still enable the funding payments to be made to providers for DAs by Medr. As the majority of degree apprentices are enrolled by 1 November during period 1, the HEPs would ensure funding can be allocated shortly after the period end. The HEPs would then receive funding for the low number of apprenticeships that start after 1 November, using data extracted through the HESA IRIS DA output, in the following academic year with that year’s starters. This is outlined further in the example in the table below and in paragraph 16.

Timeline
November 2024	HESES 2024/25 recruitment data collected for starters to 1 November 2024 and continuing from previous years
January 2025	HESES 2024/25 recruitment data verified DA funding calculated for 2024/25 starters and continuing from previous years
March 2025	DA funding paid for 2024/25 starters and continuing from previous years
November 2025	HESES 2025/26 recruitment data collected for starters to 1 November 2025 and continuing from previous years   HESA Student record 2024/25 AY data received through HESA IRIS Degree Apprenticeship output
January 2026	HESES 2025/26 recruitment data verified   DA Funding calculated for 2025/26 starters and continuing from previous years   Adjustment to 2024/25 funding based on HESA data received through HESA IRIS Degree Apprenticeship output

Question 3: Are you supportive of this method of payment for starters to 1 November in AY, with later starters extracted from HESA IRIS outputs and paid for in the next AY?

15. To enable prompt payment of DA funding in 2024-25 financial year, data will have to be returned to Medr earlier than the remaining HESES tables, and verified and signed off as final in January 2025.

16. When data are returned, we carry out a validation and credibility checking process. Once any subsequent queries have been resolved, data are sent out to authorised signatories at providers for verification. We expect the process for Table 4 to follow the timetable outlined below.

1 November 2024	HESES survey date
November 2024	HESES publication issued
20 December 2024	Return deadline
20 December 2024 to 10 January 2025	Credibility checking
10 January 2025	Verifications sent to providers
24 January 2025	Verifications return deadline

17. The information collected via HESES as in the proposed table in Annex A would include detail of the framework, pathways, course duration, student enrolments and assumed completed credit values, but would not include detail of personal characteristics which is currently extracted and analysed using the HESA IRIS DA outputs which includes full, end year data.

18. In particular, assumed completed credit values would be prepared using the guidance and mappings offered in HESES/EYM publications, which provide detailed information of how to estimate where module completion is not known due to spanning two academic years. HESES/EYM circular guidance currently contains detail of how this estimation should be managed but the publications will be further updated to directly reference requirements for DA data. Additionally HESES will be expanded to include guidance for module completion and return of associated assumed completed credit values.

Question 4: Are you content that the definitions currently included in Medr HESES and EYM guidance also apply to DA programmes? Do you have any particular structures of DA programmes that do not fit in to the Medr HESES/EYM guidance offered? (see also specific Qs in next section)

19. The bids/proposals process would continue with no changes.

20. The detailed information for monitoring purposes and end year position of student and module completion would continue as currently using the HESA IRIS end year extractions, which are reviewed and signed by HEPs.

21. Medr have also considered particular issues raised by HEPs in HE Student Review Group meetings, or directly relating to DA courses. These are outlined below and covered in questions 5, 6 and 7.

22. Completions – enrolments and credit values
2023/24 HESES guidance, Annex A, paragraph 17 states that for enrolments:
“Completion status is determined on a year of study basis, not on a course basis. Completion status is defined as follows:
– Non-completions are where students do not complete their studies due to withdrawal or dropout, or fail to take part in required assessment procedures for the year.
– Completions are all eligible students who are registered or expected to register within the academic year minus those who are expected to not complete. Any transfers between ASCs, modes or levels of study should be included.
– Partial completions: some full-time and sandwich students on taught courses that are non-completions can be counted as 0.5 of a completion if they meet certain criteria. If the course is semesterised, this is that the first semester is completed and if the course is not semesterised, that the first four months are completed.”

2023/24 EYM guidance Annex A paragraph 19 states that for credit values extracted through the HESA IRIS process:
“Credit values relating to modules started in the year are counted along with the number of non-completed credit values and the number of completed credit values is calculated.
Completion status is defined as follows:
– Non-completions are where not all of the assessment required for a module has been undertaken.
– Completions are where all assessment required for a module has been undertaken.  
– Partial completions: for modules on full-time and sandwich taught courses only, credit values for non-completed modules can be counted as partially completed if they meet certain criteria: if the course is semesterised and all required assessments due for the module during the first semester have been undertaken then the credit values for the first semester can be counted as completed; if the course is not semesterised and all required assessments due in the first four months have been undertaken and there is auditable evidence that the student was still in attendance then half the credit values for the module can be counted as completed.”

Question 5: HEPs are asked to review in particular the guidance that refers to completion of enrolments (HESES 2023/24 Annex H, paragraph 15) and completion of modules (EYM 2023/24 Annex I, paragraphs 14 to 18), and its suitability to match the DA specific structure in their provider and their ability to adhere to requirements under this guidance.

23. Non-standard academic year courses
2023/24 HESES guidance, Annex H, paragraph 4 states
“Non-standard academic years
Those students who are following programmes of study which do not coincide with the academic year (1 August to 31 July) should be counted once only for each period of up to 12 months of study. They should normally be counted in the year in which the first registration occurs and in the years including the anniversaries of the first registration. An exception to this is if they go beyond the anniversary of the start date by less than two weeks, in which case a further registration should not be returned.”

24. For clarity, a degree apprentice who started a 3 year course on 1 Jan 2025, for the purpose of returning data to HESA would be included in the student record for AYs 2024/25, 2025/26, 2026/27 and 2027/28. As the student has started on 1 Jan 2025, they would not be picked up as a new starter in HESES 2024/25 as after 1 November survey date. This data would be extracted from the HESA IRIS degree apprenticeship output in 2024/25, 2025/26 and 2026/27. All associated modules would be counted in the AY in which the modules start during the whole period of their study, this is to avoid double counting of credit values for modules that span two academic years.

25. Modules that span academic years, estimation of completion
2023/24 EYM guidance Annex A, paragraph a 20 states the following:
“When the EYM data are extracted, the number of completed credit values for modules started in 2023/24 will mostly be known. There will be some circumstances where estimates have to be made, for example, where students are on a module which spans two academic years, or where a student is eligible to take part in further assessment for a module after the end of the year in order to complete the module. In general, where estimates are used to make amendments to the extracted data, they should be based on the proportion of non-completed credits for the module in the previous year or years, or for new modules, information about similar provision in the first year of delivery. However, other methods may be used if providers believe these would provide more accurate estimates.”
“Where providers make estimates of non-completions…..they should keep auditable evidence to show the basis of these calculations.”

26. Although this guidance refers specifically to HESA IRIS extractions, the same methods should be applied to all estimation involved with module completion.

Question 6: HEPs are asked to review in particular the guidance that refers to estimating module completion (EYM 2023/24 Annex I, paragraphs 14-18) and its suitability to match the DA specific structure in their provider and their ability to adhere to requirements under this guidance. We are proposing to add an additional DA specific example in this Annex, so welcome you sharing any structures with us that we could use in the guidance update.

27. We intend to carry out a modelling exercise looking at estimation rates of DA specific module non-completion, much like we supply in HESA IRIS EYM extracts for the wider HE population. We would present our findings to HEPs for comments and would eventually be provided through the 2024/25 HESA IRIS DA output to aid providers with their data returns in futures years and/or be a source of data to check assumptions made in calculating estimates in your provider.

Question 7: Do you support Medr carrying out this estimation through the HESA IRIS degree apprenticeship outputs and do you have any comments on the current EYM estimation method that would not work well with your DA population?

Question 8: In addition to the seven questions outlined above, we welcome any further comments relating to the data capture of Degree Apprenticeships for monitoring and funding uses in Medr.

Responses and next steps

28. We are asking for responses to this consultation by 8 November 2024, to be sent to [email protected]. We are holding a meeting of the Medr student record review group on 15 October 2024 where we will run through the consultation and we welcome any comments at that meeting also.

29. We are sharing this consultation with nominated student data contacts at HEPs in addition to degree apprenticeship contacts. We encourage a co-ordinated response to capture comments which are both policy and data specific. We are also happy to meet with providers if you would appreciate a one-on-one discussion.

30. Once we receive responses we will consider them further and all changes will be reflected in the HESES publication which will be published in November 2024.

Further information

31. Any queries should be directed to Rachael Clifford (email [email protected]).