June 14, 2021

Submission from HECA to the Public Consultation on Review of Student Grant Scheme – SUSI (Student Universal Support Ireland)

    Towards Fairness and Equity for all students in Irish Higher Education

    April 2021 

    1. Introduction
    1. The Higher Education Colleges Association (HECA) is an association of thirteen established, mature privately funded higher education institutions (HEIs), providing quality assured, flexible, cost effective and focused programmes at higher education levels (between Levels 6-9 on the National framework of Qualifications) which are both accredited and awarded by Quality & Qualifications Ireland (QQI).  HECA has made a number of recent submissions to Government setting out statistical data and information on the range of programmes provided and overall contribution to the sector.  Some HECA member HEIs have been in existence for 40 to 50 years, with a well-established and credible tradition of responding to third-level educational needs of full and part time students over this period.  Member HEIs within HECA have made and can continue to make valuable contributions to both provision and the development and implementation of Government policy responses to the challenges facing Higher Education in Ireland.

    1.2 HECA welcomes the opportunity to make a submission for the independent review of the Student Grant Scheme, which was announced on October 13 as part of Budget 2021 in line with the Programme for Government – Our Shared Future (June 2020).  It is our aim to make a clear and pithy submission on behalf of students registered on QQI validated programmes of our member HEIs.    

    1. The Case of Equity and Fairness in Reviewing SUSI

    ‘The Republic guarantees religious and civil liberty, equal rights and equal opportunities to all its citizens, and declares its resolve to pursue the happiness and prosperity of the whole nation and of all its parts, cherishing all the children of the nation equally……. ‘

    The aspiration of fairness and equity of treatment for all citizens of the nation is clear in the words above taken from the Proclamation of Independence that is read from the steps of the GPO each Easter Sunday and prominently displayed on the Government website as the continuing underpinning philosophy of the State. 

    However, there is a noticeable gulf between the articulation of these ideals and how they are in put into effect by successive governments, in relation to how they treat students accessing different parts of the Irish higher education system. Two particularly glaring examples exist.

    • The first, though not specifically related to SUSI, is an example of a lack of policy perpetuating inequality and unfairness.  The Seventh Amendment of the Constitution (Election of Members of Seanad Éireann by Institutions of Higher Education) Act 1979 provided that the procedure for election that of six members of the Senate in the university constituencies could be altered by law.  It was approved by referendum on 5th July 1979 (with a 92.4% yes vote) and signed into law on 3rd August of the same year.  Nothing has happened since.  A Bill to extend the franchise to holders of degrees or diplomas accredited by Quality and Qualifications Ireland has been deferred until the end of 2021. 
    • The second, and possibly the more egregious is an example of public policy imposing inequity and unfairness on some citizens of the State is the denial of financial support through the SUSI process to financially disadvantaged learners who, either by choice or through necessity, opt to enrol in Private Higher Education Institutions. Interestingly, SUSI is an acronym for Student Universal Support Ireland, and, while it may provide support to some students, it is by no means universal. 

    In order to be eligible for SUSI funding you must be Irish, or an EU, EEA, UK or Swiss National or have specific leave to remain in the State. However, if you are an Irish national who chooses to go to an Irish private HEI either to access a particular programme, unavailable elsewhere, or because it is in reasonable proximity to home, or because a place in a public HEI is unavailable to you, you are not eligible for SUSI support.  This, despite the fact that the programme is fully validated by QQI, is appropriately placed on the NFQ and that the Quality Assurance/Quality Improvement policies and procedures of the HEI are approved by QQI following rigorous external review. These HEIs, some of which have been in existence for almost 50 years, have produced some 126,891 graduates and currently have some 27,000 students enrolled on programmes ranging from Level 6 to Level 9 on the National Framework of Qualifications.

    This submission is not a proposal for private HEIs seeking government funding.  Currently, the majority of HECA HEIs receive no direct funding from the State and, since our inception, we have maintained full responsibility for all the costs of our premises, facilities, recurrent costs and staffing and continue to do so.  The hallmark of each member HEI has been a clear demonstration of a commitment to quality and to deliver a quality student learning experience over many years.  This is underpinned by the deliberate choice of these HEIs to seek QQI approval of their quality assurance policies and procedures and gain access to QQI awards by submitting their programmes to rigorous external review and QQI validation.

    This submission, however, is not about the private HEIs, it is about the students who attend them. There is no defensible reason in our view, why these students should be prevented from obtaining support from the state other than the application of a policy that renders them inferior to students from the EU, EEA, UK (despite Brexit) or Swiss Nationals, not to mention those Irish students accepted into public HEIs. 

    Linking accessibility of student support to types of institutions, rather than the needs of students, is inherently unfair to the student. 

    Our view is simple. Funding should follow the student. Once learners have a guarantee that the higher education programme upon which they intend to register is fully validated by QQI and earns a QQI award (only possible if the private college its quality assurance approved, under statute by QQI), then learners should be able to choose the programme that best suits their needs. 

    HECA believes and note that USI support our position, that learners on QQI approved courses should not lose their supports, maintenance grants or disability grants merely because their chosen course is provided by a private HEI. One of the first encounters of student discrimination and national limits to equity of participation in higher education is at the CAO application stage where nine HEIs in the CAO system are listed as not eligible for SUSI funding. This is straight away limiting the choice for students who require student supports. 

    Private HEIs provide opportunities to students who find the public system closed to them because of capacity, CAO points, geographic constraints or because they find that it is the only institution offering the type of programme they desire. 

    The very existence of the CAO system is testament to the fact that successive Irish governments have been unable to meet soaring demand for higher education through the current public university and Institute of Technology systems. Private higher education providers have stepped into this gap, at least for the 27,000 students they currently have enrolled. HECA recognises that there is not an unlimited pot of money available to the government for Higher Education. However, it also recognises that successive governments make choices about how they will spend the money available to them. 

    What is clear, is that the government only has a limited ability to increase the places available to address the burgeoning demand and the national policy to increase access to higher education. We posit that it would be more economical and beneficial for the government to acknowledge the continuing and growing contribution made by the private HEIs and provide the much smaller SUSI subvention to students that would help their progress through their chosen college without forcing them to rely on part-time employment to support them through their course. 

    In the past, concerns were expressed of the cost to the exchequer in increasing student supports to students in the private higher education sector. However, this evaluation gave no consideration to the fact that private HEIs provide third level places at no capital or pension costs to the state and can provide a much larger role in meeting government targets to further widen the participation field in higher education if student supports available to eligible students in public funded institutions were also available to students at QQI awarded private HEIs. The average cost for an undergraduate student in a public HEI (taking all disciplines into account) would be in the region of €9,000 - €10,000 per student per year (not including SUSI costs). The average private undergraduate costs are significantly lower at €6,500 per student per year. 

    In 2017, all-party Joint Oireachtas Committee on Education and Skills report recommended to the Department of Education & Skills that students enrolled in private HEIs should be entitled to SUSI and if Student Assistant Fund if eligible. That recommendation has been ignored to date. 

    The Expert Group on the future funding for Higher Education (2016) underpinned increasing access and participation in higher education as a part of the social contract. In pursuit of this in their recommendations (Recommendation 6) they proposed:

    Examining the potential of extending support under the student grant scheme to part-time learners and learners in private institutions (our emphasis).’

    This review provides an opportunity to do this and to address an unfair and inequitable restriction on students, many of whom are forced to bear financial burdens such as a reliance on excessive part-time work, long commutes or commercial lenders that are minimised for students of similar means who are supported through the public HE system.

    As the Expert Group on the future funding for Higher Education stressed:

    A new funding model must involve a more holistic treatment of all learners


    Increasing access and participation in higher education plays a major role in driving social mobility and improving life outcomes and can be seen as a core part of the social contract.

    1. Conclusion

    HECA notes the ten Terms of Reference outlined on the following link inviting stakeholders to make a submission for public consultation: https://www.gov.ie/en/consultation/bb832-public-consultation-on-review-of-student-grant-scheme-susi-student-universal-support-ireland/#terms-of-reference.

    The first Term of Reference seems to preclude registered students in Irish state accredited privately funded college providers from being considered under this Review.  We feel that the current SUSI scheme is need of urgent review, and is out of step with the progressive approach of the relatively new Department of Further and Higher Education, Research, Innovation and Science.  For example, the new Department has recently and consistently highlighted the lack of a fully integrated third-level sector which has fostered inequality, elitism, skills shortages, stress on students and high drop-out rates in higher education.  

    HECA welcomes the Minister’s recent commitments to tackling inclusion in education, and HECA believes and proposes that established, state accredited privately funded HEIs are a part of the solution towards addressing shortfalls and capacity challenges within the system, most notably identified by nationally commissioned reports such as the Expert Group on the Future Funding for Higher Education (Cassell’s report), and the National Strategy for Higher Education to 2030 (Hunt report).  Both reports project that the total demand for higher education will significantly increase by 2030; with notable growth coming from non-traditional students such as mature students and international students, as well as increased postgraduate activity.  The need for lifelong learning, part time - flexible learning, and up-skilling among the workforce will also contribute to growth. Increased demand will be very good for higher education, but it will also bring serious challenges in terms of capacity (e.g. infrastructure, human resource practices, funding streams, modes of learning etc).  

    Our member college providers have worked in harmony with sectoral agencies, other representative bodies, and of course government departments to act responsively, responsibly, compassionately, and innovatively to the COVID pandemic crisis without any burden on the exchequer.  Despite the significant stress and additional workload imposed on staff across the sector as a result of COVID, HECA institutions have again proven their dedication, flexibility, and agility in responding.  Our member college providers have long demonstrated their commitment to contribute and respond in the national interest, through initiatives such as Springboard, ICT Skills Conversion, and the Human Capital Initiative.

    In closing and to be clear, HECA does not feel it is reasonable, tenable, equitable, or fair for registered students on state accredited and validated programmes provided by privately funded HEIs to be excluded from the SUSI scheme, any review process of the SUSI scheme, or any future form of the SUSI scheme.  HECA recognises a real opportunity for a complete review of SUSI and calls for this review not to leave anybody behind within the system.  


    Please note that HECA member HEI, the National College of Ireland, are making a separate submission to the Public Consultation on Review of Student Grant Scheme – SUSI (Student Universal Support Ireland) and are not included in this submission.


    Patricia O Sullivan
    Executive Director
    HECA, Higher Education Colleges Association
    M: +353 86 170 8453Email: [email protected]

    crossmenu linkedin facebook pinterest youtube rss twitter instagram facebook-blank rss-blank linkedin-blank pinterest youtube twitter instagram