Disability Equality Impact Assessment

Disability Equality Impact Assessment Report of

The Open University Student Support Policies and Processes

July 2010

1 Contents Page No

1. About this Impact Assessment 3

2. Aims of the policies/processes 3

3. Equality relevance 6

4. Data, evidence and feedback used 7

5. Assessment of impact 7

6. Promotion of equality 18

7. Consideration of alternatives 19

8. Formal consultation 20

9. Decisions and actions 20

10.Monitoring arrangements 26

11.Publishing 27

12.Next review 27

Appendix 1 Open to your needs – Statement of Service 28

Appendix 2 Summary of data, evidence and other sources 34 of feedback

Appendix 3 Disabled Student Strategy Advisory Group (Separate (DSSAG) report August 2009 - registrations and document) completions for UK and non-UK students who have declared a disability or have additional requirements for the period 2003/04 to 2007/08 with provisional registration headcounts for 2008/09

Appendix 4 Summary of feedback from the formal consultation with disabled students 37

2 1. About this Impact Assessment This Disability Equality Impact Assessment relates to the Open University (OU) student support policies and processes that are delivered through Student Recruitment and Financial Support, Disabled Student Services and Assessment, Credit and Awards. These functions are the overall responsibility of the Director, Students.

It does not include teaching support for disabled students as the Student Support Review and the Associate Lecturer Role Review are currently underway and equality standards will be integrated within these reviews. This impact assessment was led by the Head of Disabled Student Services with a working group of staff from the relevant areas of Student Services and the Equality and Diversity Office.

Queries about this report or comments about the content should be sent in writing to: The Head of Disabled Student Services, The Open University, East Campus, Milton Keynes, MK7 6BY. 2. Aims of the policies/processes

2.1 Background The Office for Disability Issues estimates that in 2007/8 there were around 9.8 million disabled adults in Britain, of whom over 5 million are over state pension age. This estimate covers the number of people with a longstanding illness, disability or infirmity, and who have significant difficulty with day-to-day activities.

The Open University is distinctive among higher education institutions (HEIs) in the UK, in that we teach primarily at a distance and have no academic prerequisites for admission to most undergraduate courses. The majority of crucial interactions with students are managed through Student Services, both in regional and national centres and in the offices based at Walton Hall. We have around 157,000 UK undergraduates and 11,000 postgraduate students. On average more than 10,500 students annually declare a disability, health condition, mental health difficulty or specific learning difficulty (such as dyslexia) which is the largest disabled community of any UK university. The University has seen a steady growth in disabled student numbers over the last year – with registered students peaking at 11,983 in November 2009 and over 3,000 of these in receipt of a Disabled Students’ Allowance.

The Disability Equality Duty has additionally contributed to developments in this area. The anticipatory nature of the legislation means that the needs of some students will be met automatically. However, for many students, adjustments need to be made in response to their particular requirements. The OU has a long-standing procedure for asking students to identify their support requirements and staff work with a genuine understanding of the social model 1of disability. We strive to share good practice and embed strategies at operational and strategic level.

1 The social model focuses on the limitations of society. Barriers imposed by society are the disabling factor, not the impairments. In other words, the impairment is not the barrier.

3 Most of the activities managed by Student Services are carried out in collaboration with colleagues in other parts of the University, particularly those in academic units.

2.2 Core purposes and priorities Student Services’ core purposes (extract from Student Services Intranet) are to provide:

 excellent support services for students

 excellent teaching infrastructure and support for student learning

and to do so in the most personalised way possible.

2.3 Student Recruitment and Financial Support (SRFS) Student Recruitment and Financial support aims to provide a service for enquirers and students which ensures: “a consistent, timely, professional, personalised service from staff who are genuinely interested in helping them, where they get the right answer first time every time.” SRFS is responsible for: the provision of services to students, enquirers, faculties and other units to support the University in meeting its student number targets, for ensuring that students and enquirers receive the information and advice they need to register on courses and qualifications that are right for them, and ensuring that student financial support is administered in accordance with the criteria set by the Fees and Financial Support Advisory Group.

Financial support can be provided by the OU or government, subject to eligibility conditions, to help pay tuition fees, study costs, and other expenses. OU funds can be used to top up the support given by the government to students on low income. In England, Wales and Northern Ireland, OU discretionary financial support exists to aid the recruitment and retention of widening participation students and the policy is designed to be means tested and based largely on residency criteria, household income and study history/intentions. The only financial support policies that specifically relate to disabled students are:  to provide discretionary fee support to allow disabled students to undertake a second degree  to use Access to Learning funds to top up Disabled Students’ Allowances (DSA) awards or to support students who can no longer complete their qualification within the DSA limits.

The purpose of these policies is to encourage participation from disabled students and to maximise widening participation and teaching grant income. Disabled students are means tested for support from the Access to Learning Fund.

DSAs are government-funded allowances provided to ensure that UK domiciled disabled students in higher education have the same opportunity to succeed in their studies as non-disabled students.

For OU students resident in England, Wales and Northern Ireland, the Disabled Students’ Allowances Office (DSAO) assesses claims for Disabled Students’ Allowances

4 and makes payments on behalf of the Department for Business, Innovation and Skills (BIS) to eligible OU students in England, Wales and Northern Ireland.

The DSA Office works within the Student Support Statutory Regulations and DSA guidelines at:

http://practitioners.studentfinanceengland.co.uk/portal/page? _pageid=133,4210372&_dad=portal&_schema=PORTAL

In Scotland, DSA is administered by the Students’ Awards Agency for Scotland (SAAS) for the Scottish Government. For information go to:

http://www.student-support- saas.gov.uk/student_support/special_circumstances/pt_apply.htm

2.4 Disabled Student Services (DSS) The mission of Disabled Student Services is to enable disabled students to study and achieve their goals and aspirations on an equal basis to their peers. Its values are to be student centred, responsive to change and collaborative. It aims to provide good quality, timely advice, services and personalised support to students and to develop its staff to their potential.

Disabled Student Services delivers its services through four teams: Disability Resources Team; Disability Advisory Services; the Access Centre; and Curriculum Access. Staff provide a wide range of services and support to disabled students requiring alternative format course materials and/or auxiliary aids in order to study successfully at home, at tutorials or at residential schools. In addition, they provide information, advice, guidance, support and professional development opportunities to colleagues supporting disabled learners. The provision of a high quality integrated service is a high priority. ‘Open to your needs’, the Disabled Student Services statement of service (attached as Appendix 1) summarises the support services and facilities available to disabled students and is sent to all students at reservation. The ‘Meeting your needs’ booklet, which has more detailed information, is sent at registration stage to all students who have disclosed a disability or additional requirement.

2.5 Assessment, Credit and Awards The Examinations and Assessment Section is responsible for the implementation and delivery of the University’s policies and procedures for the assessment of its students. This involves the processing of all items of assessment (both continuous and end-of- course assessments); the organisation of examinations; coordinating the marking of end- of-course assessments; and supporting the processes leading to the determination of course results.

For disabled students, Examinations and Assessment provides a comprehensive range of alternatively-formatted examination question papers and, in conjunction with regional/national centres, supports a wide variety of arrangements such as additional time, alternative venues and alternative methods of accessing or recording assessment items, to enable students to complete their end-of-course assessment. All disabled

5 students are sent a copy of ‘Meeting your Examination Needs’ setting out support arrangements. Students are made aware of the support arrangements for continuous assessment activities and projects through the ‘Meeting your Needs’ publication.

The Qualifications and Ceremonies Centre is responsible for the provision of information on, and the conferring and certification of, the University’s academic qualifications and the organisation and management of the degree ceremony programme. The Credit Transfer Centre is responsible for providing advice and support to students on the transfer of credit. Screening for disability equality relevance has been undertaken for the management of degree ceremonies and the regulations relating to credit transfer. This screening has not revealed any adverse impact requiring a full impact assessment.

2.6 Regional and national centres There are thirteen regional and national centre teams of staff with specialist knowledge and experience who are available to provide information, advice and guidance to students and tutors. As part of the University’s Learner Support Framework, they coordinate the setting up of study support for disabled students – including arrangements at tutorials, day schools and residential schools, and special examination and assessment arrangements. The work has become increasingly complex as courses have diversified, as technology has advanced, and as the impact of the move to e-learning is becoming better understood.

2.7 Key performance indicators Key performance indicators on the Vice-Chancellor’s Executive dashboard with regard to disabled students are:

 Percentage of new UK undergraduate students with declared disability - with a desired steady trend.  Percentage difference between course completion rates for all UK students with and without disabilities with a desired downward trend.  Percentage of students in receipt of a Disabled Students’ Allowance.

3. Equality relevance These policies and processes are considered to be highly relevant to disability equality because the OU as a distance learning organisation, with its unique study support system through over 7,000 associate lecturers, provides an effective way for disabled students to study on an equal basis with non-disabled students. Accessibility is key to providing greater equality for disabled students. With over 10,000 disabled students there is the potential for discrimination to take place, particularly forms of indirect discrimination if individual needs are not identified and/or supported appropriately. These policies and processes also make a significant contribution to the promotion and achievement of equality of opportunity for study for disabled students through: actions to increase and encourage participation; actions that challenge known differences in outcomes by the provision of support and other services; actions to anticipate needs and make reasonable adjustments.

6 4. Data, evidence and feedback used Students who disclose a disability or additional requirement(s) are identified on Circe2 or VOICE3 with a disability or additional requirements (DAR) marker in their file. Students may have more than one disability. Not all students with a DAR marker request support or reasonable adjustment. The Student Registration & Enquiry Service does an annual ‘data sweep’ among students to check that we hold correct information about them, including confirming their disability status.

Appendix 2 lists the student data analysed by disability status, other sources of feedback and external benchmarks that have been used for this assessment. Attached as Appendix 3 is the 2009 annual report to the Disabled Student Strategy Advisory Group (DSSAG) which sets out detailed registrations and completions data for UK and non-UK students who have declared a disability or additional requirements over the academic years 2004/05 to 2007/08. Provisional registration headcounts for 2008/09 are also provided. The 2009 Equality and Diversity Annual Report Statistical Digest for the period 2003/04 to 2007/08 which is available on the Equality and Diversity website at http://www.open.ac.uk/equality-diversity/p6_1.shtml provides participation, course completion and academic attainment data for UK undergraduate and postgraduate students analysed by disability status.

5. Assessment of impact Key issues identified in the data and feedback analysed are as follows:

5.1 External benchmarking

a) The quality of the work of Student Services has been recognised in all the subject reviews undertaken by the Quality Assurance Agency, which has consistently rated Student Support and Guidance at 4/4. b) In addition, the University was ranked second (out of 259 institutions) for overall student satisfaction in the 2008 National Survey of Higher Education Institutions (HEIs) in the UK. 94% of OU students said they were satisfied overall (almost 7000 OU students took part in the survey). The results of the 2009 National Survey showed that overall satisfaction had remained at 94%, the third highest rating amongst all UK HEIs. c) The OU Access Centre was successfully accredited in its 2009 DSA Quality Assurance Group (DSA-QAG) audit and this is recorded on the DSA-QAG website. A review of the OU Access Bus (mobile assessment vehicle) was included in the audit.

2 Circe is an OU administrative system for staff 3 VOICE is the OU’s customer relationship management system to record student and tutor contact

7 5.2 UK and non-UK Disabled students – participation

a) Disabled student registrations as a proportion of total undergraduate student registrations has been increasing slightly year on year from 5.9% in 2004/05 to an estimated figure of 6.3% (2008/9). b) There have been over 10,000 disabled UK and non-UK students registered at the stage of one third of the way through a course (referred to as ‘at one third’) for the previous five academic years. At November 2009, there were 11,435 disabled students at registered status. This figure fluctuates monthly as students enrol and withdraw. This suggests we are competing successfully with other HEIs. However we have a much smaller proportion of students in receipt of a Disabled Students’ Allowance compared to mainstream HEIs. This is being addressed (see DSA section 5.9). c) As set out in Chart 1 below the number of continuing disabled student registrations has steadily increased from 7,960 in 2004/05 to 8,895 students in 2007/08. The number of new disabled student registrations has varied around 2,100 for the past four years, although provisional data for 2008/09 suggests a slight increase in the number of new disabled students for that year, to 2,435. This indicates that we are meeting the key performance indicator of the percentage of new undergraduates remaining ‘steady’.

Chart 1 New and continuing disabled student registrations 2004/05 – 2008/09

DAR student registrations by new and continuing

12,000

10,000

t 8,000 n u o

c 6,000 d a e

H 4,000

0 Continuing New

2004/05 7,960 2,051 2005/06 8,049 2,064 2006/07 8,355 2,270 2007/08 8,895 2,116 2008/09 (prov.) 9,535 2,435

d) Of the disabled students registered at one third, around 80% are continuing students and just over 20% are new students. These percentages have remained similar across the five years 2004/05-2008/09.

8 e) Each year the proportion of postgraduate students declaring a disability increases and is at 4.5% in 2007/08 from 3.1% in 2003/04. f) As set out in Table1 below, the disabilities reported most frequently by students are fatigue/pain, mobility, and in recent years, mental health. There have been increases in the number of students declaring dyslexia, fatigue/pain, manual skills, mental health, mobility and unseen disabilities since 2004/05. The distribution of specific disabilities differs from that of mainstream universities with a relatively low proportion of students with dyslexia but relatively high proportion of students with multiple disabilities. Nearly half of all students across HEIs declaring a disability were returned as having a ‘specific learning difficulty e.g. dyslexia’ with ‘an unseen disability (e.g. diabetes, epilepsy, asthma) as the second most commonly recorded at 17%4. At the OU the total number of new and continuing registered disabled students in October 2009 was 11,435 and, of these students, 22,492 disabilities or additional requirements were declared. (A student may have one or more disabilities.)

Table 1 Disabilities declared by OU students at October 2009 Category Total % Category Total % Sight 1213 5 Mental Health 3462 14 Hearing 920 4 Personal Care 929 4 Mobility 3637 15 Fatigue/Pain 5003 19 Manual Skills 2432 10 Other 2155 9 Speech 471 2 Unseen Disability 1521 6 Dyslexia 2611 11 Autistic Spectrum 138 1

g) The headcount figures for 2007/08 and 2008/09 (provisional) show that the number of female disabled students registered is more than double the number of male disabled students. For example, in 2007/08, there were 7,424 female students declaring a disability, compared to 3,587 male students. The OU student population as a whole has a higher proportion of female students and a higher proportion of female students declare a disability. h) The highest proportion of disabled students can be found in the Arts Faculty with 9.0% (in 2007/08). The Mathematics, Computing and Technology faculty and the OU Business School have the lowest proportion of disabled students, 4.6% and 4.7% respectively in 2007/08. Students can study in more than one Central Academic Unit (CAU), and are counted once for each CAU in which they study. A recent external study 5 suggests that disabled students are more likely to study the creative arts than any other subject. Across the UK, 4.6% of students doing IT-related degrees have disabilities, compared with 9.4% in creative arts and design and 7.7% in history and philosophy. i) The numbers of disabled student registrations show a spread across the different age categories, with the youngest age group showing the smallest percentage of

4 Equality Challenge Unit ‘Equality in Higher Education: Statistical Report 2009’ at http://www.ecu.ac.uk/publications/equality-in-he-stats-09 5 Analysis by Danielle Farrel, Research Assistant and co-authored by John Robertson, reader in media education at the University of West Scotland, reported in the Times Higher Education on 11th March 2010.

9 disabled student registrations (0.7% in 2007/08) and the oldest age group of 65 years and over showing the highest percentage of disabled student registrations (14.3% in 2007/08), as would be expected. j) The data on disabled student registrations and ethnic group show there is a lower percentage of disabled students from black and minority ethnic groups (4.7% in 2007/08) than from white ethnic groups (6.4% in 2007/08).

5.3 UK and non-UK disabled students – course completion a) Overall completion rates increased by 1.3% from 69.1% in 2007/08 to 70.4% in 2008/09. Undergraduate completion rates as set out in Chart 2 showed the same trend as overall completion rates for the three years to 2008/09; an increase of 1.7% from 68.5% in 2007/08 to 70.2%% in 2008/09. Undergraduate completion rates for disabled students also show an improvement from 60.9% in 2007/08 to 62.3% in 2008/09 with the gap in completion rates between disabled students and non-disabled students reducing from 8.2% in 2007/08 to 7.9% in 2008/09. This indicates that the key performance indicator for a desired downward trend in % difference between course completion rate for all UK students with and without disabilities is being met.

Chart 2 Undergraduate completion rates for students with and without disabilities

0% Not Disabled Disabled 2006/07 68.5% 60.9% 2007/08 68.7% 60.5% 2008/09 70.2% 62.3%

b) OU students with mental health difficulties or disabilities requiring personal care have lower completion rates than students with specific learning difficulties such as dyslexia. At the same time, students with specific learning difficulties such as dyslexia show lower attainment rates than non-disabled students. In response, Disabled Student Services is putting processes in place from 2010 onwards to improve proactive support, in particular, for students with mental health difficulties and specific learning difficulties. An Action Plan is being developed to take forward the outcomes of a 2009 survey for students with mental health issues.

10 c) For the year 2006/07, completion rates were lowest for postgraduates who reported mental health difficulties (61.3%), and highest for those postgraduates reporting dyslexia (74.5%). d) The completion rates for disabled continuing and new students have remained reasonably stable over the last four years, around 61% and 65% respectively. For new students, the completion rate for disabled students and all students is reasonably close (64.7% and 68.1% respectively for 2007/08). For continuing students there is a larger gap in completion rates between disabled and all students (61.5% and 70.6% respectively for 2007/08). e) Completion rates are approximately 10% higher for disabled postgraduate students than disabled undergraduates (71.7% and 61.3% respectively). f) Disabled student completion rates are similar across age groups and genders. The completion rates for disabled female students have remained around 62% over the previous four years. The completion rate for disabled males has slightly increased (from 58.6% to 61.2% over the last four years), to bring it closer to the female rate. Disabled students in both groups have a lower completion rate compared with the equivalent overall student group. In this case, the difference between the two female groups and between the two male groups is the same (both have a mean difference of 8.3% across the four years). g) There is a slightly smaller gap in completion rates between disabled white and disabled Black and Minority Ethnic (BME) students (5.3%, 2007/08) than there is between all white and all BME students (7.2%, 2007/08). h) Completion rates for disabled students by Central Academic Units (CAUs) fluctuate slightly from year to year. In broad terms, disabled students from the Arts CAU have the highest completion rates; OU Business School rates have been decreasing over the last four years; and Science and Maths, Computing and Technology have increased. The sharing of information across CAUs is a key part of our strategy to promote equality. i) In the 2008 Withdrawal Survey 632% of disabled students gave a physical/mental health difficulty, health condition or specific learning difficulty as the factor that most influenced withdrawal and 41.8% gave family/life events/unexpected family illness as the factor that most influenced withdrawal from a course. 3.6% of disabled students responding gave the course’s teaching materials and 2.3% the course’s study support for learning as the factors most influencing withdrawal. j) In the 2008 Courses Survey 49.2% of disabled students were likely to find the workload on their course higher than expected compared with 39.6% of non- disabled students, and 44.3% of disabled students found the course more difficult than expected compared with 36.2% of non-disabled students.

6 There was a small number of responses from disabled students to this survey- 344 in total compared to 1480 non-disabled students.

11 5.4 Academic attainment UK students Attainment rates on Level 1 courses (measured by the number/proportion of students who passed their course) for UK students (disabled and non-disabled) rose in 2007/08. The difference between disabled student and non-disabled student pass rates has narrowed slightly from 3.6% in 2006/07 to 3.5% as set out in Table 2 below. However, in 2007/08 good pass rates (a good pass is defined as a distinction and grade 2 pass or distinction and merit pass) on Level 2 and 3 courses have fallen for disabled students in the UK. As set out in Table 3 below the difference was at 7.3 percentage points compared to 5.2 percentage points in 2006/7 which is the highest it has been in the last five years. Across HEIs the percentage of students obtaining a first or upper second class honours degree was lowest at 44.4% for part-time degree qualifiers known to have a disability7.

Table 2 Pass count in FTEs and pass rates for all UK students on Level 1 courses by disability

2003/04 2004/05 2005/06 2006/07 2007/08 No. % No. % No. % No. % No. % Disabled 727.9 88.3 697.2 87.7 758.5 89.5 852.2 88.0 860.5 88.6 Non- disabled 12485.7 93.4 11961.7 92.4 13271.9 92.4 14629.7 91.6 14578.3 92.1 Total 13213.6 93.1 12658.8 92.1 14030.5 92.2 15481.9 91.4 15438.9 91.9

Table 3: ‘Good pass’ count in FTEs for all UK students on Level 2 and 3 courses by disability

2003/04 2004/05 2005/06 2006/07 2007/08 No. % No. % No. % No. % No. % Disabled 562.6 39.1 583.9 40.3 583.5 40.2 632.6 41.2 640.0 39.7 Non- disabled 10907.5 45.6 10286.6 45.7 10051.9 47.4 9949.5 46.4 10240.7 47.0 Total 11470.2 45.3 10870.5 45.4 10635.4 46.9 10582.1 46.0 10880.8 46.5

Attainment rates among all UK postgraduate disabled and non-disabled students have increased, particularly for those with a disability. For the second year in succession disabled students have a higher attainment rate than those without a disability.

5.5 Registration support As set out in Chart 3 registration methods used by students declaring a disability or additional requirement in 2009 were split into: paper 63% (11,902); online 19% (3,629); and telephone 18% (3,387). Registrations for students applying for financial support were paper-only until autumn 2009 but can now be made online which may make it easier for some students who may previously have had difficulty filling in a form. Over 1,100 alternative-format registration-related mailings, and 17 alternative-format publications (such as undergraduate prospectuses) were sent out in 2009. Generally the number of alternative-format communications requested has remained constant since the system was introduced at the end of 2008. At February 2010, 265 students appeared on VOICE with an alternative-format marker.

7 Equality Challenge Unit ‘Equality in Higher Education Statistical Report 2009’at http://www.ecu.ac.uk/publications/equality- in-he-stats-09

12 The low number of alternative-format requests could indicate that our main methods of communication and registration are meeting the needs of the majority of students. There is an opportunity on the Facility Request Form 1 for students to tick a box to indicate that, where information is normally sent out as a paper communication in standard print, they need it in an alternative format. With regard to alternative-format course materials, the Services for Disabled Students website provides a facility for students to enter a course code and check the alternative formats available for that course. The ‘Meeting your needs’ publication also contains an insert indicating the alternative formats available for individual courses.

Chart 3 Student Registrations

5.6 Assessment and award support a) The redeveloped Additional Examination Arrangements system (ADAR) was implemented in April 2009. This supports management information on: alternative arrangements; question-paper formats; and the appointing of examination invigilators. The ADAR system has also improved the ability to match the skills of individuals acting as scribes. In 2008, 825 alternative-format question papers (such as Braille, audio, enlarged or coloured) were provided, and 1,357 alternative-format answer papers (such as WP/Typed answers, amanuensis). In 2009, 829 alternative-format question papers and 1,376 alternative- format answer papers were provided. Feedback loops are closed via invigilator reports and special circumstances procedures. Where relevant these are referred to regions and nations so that they may be acted on at the student’s next examination opportunity. Students are also invited to contact their regional or national office when considering their examination requirements to discuss any amendments to previous arrangements. Also in 2009, 2423 students were allowed extra writing time and 2,122 students were allowed rest breaks, benefitting 3,137 students in total. b) Student requests for arrangements that fall outside existing policy are considered by the Exceptional Examination Arrangements and Special Circumstances Sub-Committee (EEASCS). Examples relating to disability would include requests for permission to use additional materials and tools in the examination, special circumstances information received after a course result has been awarded etc. Should an issue require a review of existing policy, a paper is presented by the Sub-Committee to the Assessment Policy Committee (APC). As a matter of course the Sub-Committee submits an activity report to

13 each APC meeting. These reports, together with the minutes of the APC meetings, were reviewed for this Assessment Report c) During 2009, 29% of the 6,024 special circumstances forms received by Examinations and Assessment (covering continuous assessment, examinations and end-of-course assessment) were submitted by students with a declared disability. An analysis took place of special circumstance forms submitted by students on selected Level 1 courses relating to courses with a June 2009 examination or end-of-course assessment. This demonstrated that where students felt their disability or external factors had hampered their performance, they often failed to be specific about how this impacted on their performance and did not explain it in relation to any additional arrangements or DSA support. In some cases it was the onset of additional illness that had exacerbated their underlying condition, while some students had encountered a disability during their time on a course, and some students had become full-time carers through accident or injury of a family member. d) A full review of accessibility of degree ceremony platforms to disabled students was undertaken in 2005 (and has since been regularly reviewed). In 2011 there will be just three venues which do not have wheelchair access to the stage. These are the Palais de Congres at Versailles, Milton Keynes Theatre and Ely Cathedral. For each of these venues, full information about accessibility is given prior to the booking process to allow graduates to choose an alternative venue should this be a consideration. The accessibility of the stage is a factor which is taken into consideration when choosing new venues. The University now has a policy of only taking on new venues which are fully accessible and to continue to encourage existing venues to improve their accessibility. e) The analysis of official examinations and assessment complaints during the period April - September 2009 demonstrates the kinds of issues that have frustrated students, but does not flag up any significant disability-related impacts which need to be addressed.

5.7 Study support Disabled students receive a wide range of study support each year including course material in alternative formats; equipment /aids and non medical helper support at residential school; equipment loan for home study; and communication support at tutorials/residential schools. The proportion of alternative-format course material available increased by 9.5% in 2008/09 (exceeding the annual target of 3%) and alternative-format versions of all main course materials for residential schools were produced. The University cannot reasonably provide all course materials, publications, etc. in all alternative formats. Disabled Student Services publishes details of the formats available for course materials. Tutors are expected to contact their students before course start to discuss any requirements for alternative-format handouts etc. at tutorials. If, however, students discover at a later date that they require an alternative format, they can contact their tutor and ask for them to be provided. The Disabled Student Services website was redesigned during 2009 and included more details about the range of support available for disabled students. Extra links between the online prospectus and the Disabled Student Services website were added in order to signpost information for disabled students as early as possible when making their choice of courses. A feedback mechanism is also in place.

14 5.8 Complaints and Appeals Whilst there is a higher proportion of complaints and appeals from disabled students than might be expected in comparison with the student population –166 disabled students (23% of the total complaints) raising Stage 1 complaints in 2009) – only three related to additional requirements or permanent disability. In addition only 35 of the 166 went on to become Stage 2 complaints and 23 to Stage 3. 13 of these went to the Office of the Independent Adjudicator and, of those, seven related to the end-of-course assessment, three to continuous assessment, two to administration and advice, and only one to additional requirements. There is evidence of a rise in all student complaints in HEIs linked to an increased awareness of rights.8 It is important to be able to identify clearly whether a complaint from a disabled student is actually disability-related, given that a proportion of complaints can stem from a combination of issues. There is scope for identifying how complaints processes are informing practice and leading to business improvement. Disabled Student Services and other units work closely with the Complaints and Appeals office to investigate and resolve complaints from disabled students that are directly related to the student’s disability.

5.9 Disabled Students’ Allowances (DSA) The number of active DSA students is around 32% of the total OU disabled student population. Over the past three years, the number of students receiving DSA has been increasing, with provisional figures for 2008/09 of 3,206 students indicating a 7.4% increase from 2007/08. This suggests that publicity and information about DSA and other financial support is being more effectively targeted.

All student feedback is scrutinised to check if policy or procedural changes should be reviewed and implemented where appropriate. The majority of the feedback we receive relates to guidance and statutory regulations published by the Department for Business, Innovation and Skills (BIS). The DSA Office makes awards based on this guidance and on behalf of DBIS. Therefore the majority of student dissatisfaction is in reality directed at government policy rather than OU policy. Criticism from students typically relates to equipment that a student would prefer to have, rather than what has been recommended in the Needs Assessment Report. The DSA Office can only consider paying for items that are an additional cost that a student is obliged to incur because of their disability, and not for upgraded items that the student may wish to have. Traditional perceived barriers to DSA uptake include: the evidence requirement; the format, size and nature of the application form; perceptions of the time the process takes; and a misunderstanding that DSA is means-tested and age-related. The time it takes to process a DSA involves a variety of stakeholders which means the processing timeline is heavily dependent on access centres, students and suppliers.

A pilot research project was undertaken in the Spring of 2010 to establish the reasons why current OU students did not apply for a Disabled Students’ Allowance (DSA) even when they were eligible to do so. The results of the pilot are currently being analysed. The outcomes of the analysis combined with more targeted DSA promotional activity will hopefully increase the number of students applying for and being awarded a DSA. Work jointly being undertaken by Disabled Students’ Allowances Office will in the future

8 Article in Times Higher Education on 8/2/2010 by Professor Frank Furedi, Professor of Sociology, University of Kent

15 increase the awareness of the benefits of a DSA amongst the disabled student community.

5.10 Consultation The range of opportunities for disabled student involvement is set out in Appendix 2. Key issues that have been identified from this feedback are as follows:

a) DSS residential schools feedback questionnaires – questionnaires from disabled students and assistants at residential schools are read individually as part of the residential schools service review process. Any issues that arise are investigated and a response sent to the student/assistant as appropriate. The Disability Resources Team provides an annual summary to the Health and Safety Teaching Advisory Group highlighting any concerns. DSS staff also attend an annual post-residential schools meeting where issues and concerns that have emerged from disabled student feedback mechanisms are addressed. The Resources Team has responded to negative feedback by improving the distribution of the booklet ‘Meeting your needs at Residential School’. From 2010 the publication is being sent to students using their preferred communication method. The majority of students now receive an electronic mailing prompting them to sources of information and the completion of the Facilities Request Form (FRF) in readiness for their residential school. The new process has reduced administrative time whilst delivering information to students through their preferred choice rather than through what was the standard OU distribution channel. b) DSS equipment loans - following student feedback our despatch and recall processes have been streamlined to ensure a more efficient and effective service to students. c) Alternative formats 2009 – 80% of mailings for the first dispatch (in October 2009) of comb-binding for each course were sent before course start (60% at least four weeks before) with the remaining 20% sent at course start. For November 2009 88% of comb-binding mailings were sent before course start (83% more than four weeks before course start), 4% at course start and 8% after course start. The 8% equates to four courses: two of which were special requests by students after course start, one course had no books available for comb-binding and one was an error in instructions. Late dispatch of materials for October and November occurred for students who registered after the initial mailing dates. The Resources Team received feedback from students stating that they have noticed an improvement in the comb-binding service. The Resources Team will continue to monitor student feedback received. d) End-of-course survey 2008 – of the respondents 96% of disabled students agreed that course choice information, and information for disabled students, in OU publications or OU websites is very/fairly accurate. e) Course experience survey (sponsored by Disabled Student Services) - mailed to 1,000 disabled and 1,000 non-disabled students in November 2008. Where comparisons have been made between disabled and non-disabled students regarding their access to computing equipment, and confidence in using that equipment, there is little difference. Some concerns were raised about some of the

16 supporting study booklets, enlarged print materials and timeliness of support. All services in DSS have been evaluated over the past two years via process reviews and an Implementation Plan is in place to address issues. f) 2008 Withdrawal Survey - (small number of disabled student responses 344 in total compared to 1,480 for non disabled students) - there was minimal percentage point difference with the level of satisfaction (% agreed) with aspects of the OU study experience for disabled students and non-disabled students. g) E-forums - the comments and discussion on the three pilot e-forums for disabled students in 2009 provided valuable feedback in terms of the issues and challenges that students contend with during their studies and anecdotal descriptions of satisfaction or dissatisfaction with the service and support they receive. Disabled students can experience higher levels of feeling socially isolated from their study peers. The high level of positive correspondence exchanged between students on the e-forums to (for example, encourage each other with trying a new approach or making an application for financial support) can be viewed as an important source of support for disabled students. h) Early Course Experience Survey 2009 - this survey has made a significant departure in delineating responses from students who have and have not officially disclosed a disability to the OU. This serves to provide ‘cleaner’ data on the opinions of disabled students with declared disabilities. At the same time, 3% of the survey respondents (70 students) declared a disability within the survey but had not declared this to the University. Although overall numbers of disabled student respondents were small, the survey indicated high levels of satisfaction with the disabled student support they received, for example with assistive technology and equipment. i) Mental Health Survey 2009 - a variety of themes emerged including improving communications about the support students can receive from the University, and difficulties in attending tutorials/residential schools. The main focus of the feedback relates to positive and negative tutor support which is not the subject of this Impact Assessment and will be considered separately. A large proportion of the students who responded were appreciative of the input by the OU.

5.11 Summary a) Disabled student registrations as a proportion of total UK and non-UK undergraduate student registrations have been increasing slightly year on year. b) The number of continuing disabled student registrations has steadily increased, and the number of new UK and non-UK disabled students for 2008/09 has increased slightly. c) The number of students receiving a Disabled Students’ Allowance has been increasing although at around 32% of the total OU disabled student population this is a much smaller proportion of students in receipt of a DSA in comparison with mainstream HEIs. d) The proportion of alternative course material available increased by 9.5% in 2008/09 exceeding the annual target of 3% and alternative format versions of all main course materials for residential schools were produced.

17 e) Undergraduate completion rates for disabled students show an improvement with the gap in completion rates between disabled and non-disabled students reducing slightly to 7.9%. f) OU students with mental health difficulties or disabilities requiring personal care have lower completion rates than students with specific learning difficulties such as dyslexia. g) The difference in attainment rate on Level 1 courses between disabled and non- disabled UK student pass rates has narrowed slightly. h) The good pass rates on Level 2 and 3 courses have fallen for disabled students and at 7.3 percentage points in 2007/08 is the highest it has been in the last five years. i) For the second year in succession UK postgraduates with a disability have a higher attainment rate than those without. j) In 2009, 829 alternative-format examination question papers and 1,376 alternative- format answer papers were provided. Also in 2009, 2,423 students were allowed extra writing time and 2,122 students were allowed rest breaks during exams. k) Whilst there is a higher proportion of complaints and appeals from disabled students than might be expected in comparison with the student population, the majority are not complaints about disability-related issues and the proportion of students that take their complaint beyond the first stage is small. 6. Promotion of equality Disabled Student Services, Student Registration & Financial Support and Assessment, Credit and Awards have the potential to make a positive impact on equality for disabled students through the access support provided. Their policies and processes make a significant contribution to the promotion and achievement of equality of opportunity for study for disabled students, through the provision of a wide range of support services which directly enhance the capabilities of disabled students.

Actions being taken to support the promotion of equality for disabled students and sharing best practice include: a) Cluster group meetings – three annual meetings of staff from regional/national centres working with, and supporting, disabled students, as well as Student Registration & Enquiry Service staff, to exchange information, address issues and share good practice. b) Annual Disability Conference - offering workshops to enhance staff skills and knowledge, and address issues for continuous improvement. c) Accessibility workshop for course managers and programme managers – providing exemplars of good practice in incorporating reasonable adjustment into course material development for key faculty staff. d) Accessibility and assistive technology workshops for LTS project management staff - examples of reasonable adjustments in course materials discussed and explained.

18 e) Annual Introduction to Course Team Chairing – embedding the needs of disabled students into courses. f) Disabled Student Services working groups – a Visual Impairment Working Group, a Mental Health Working Group, and a Specific Learning Difficulties Working Group provide a platform for sharing and disseminating exemplars of good practice in reasonable adjustments to faculty, regional and national staff. All have disabled student representatives. g) Disabled Student Strategy Advisory Group (DSSAG) - focuses on internal and external developments of a strategic nature which might impact on the learning experience of disabled students at the OU. Membership includes OU student representatives, external disability experts and OU staff with a remit of, or experience in, disabled student support. h) Equality and Diversity Management Group - the Head of DSS is a member. i) OU Students’ Association meetings - meetings are held with Head of Equality and Diversity office and Head of DSS. Key staff are invited to report on specific issues. j) Training/ workshops for regional/national and central staff - offering disability equality training, specialist workshops with strategies for interacting effectively with disabled students. k) Recent initiatives to improve support and services and accessibility of the curriculum are embedded in the DSS Process Reviews and Digital Audio Project. l) Assessment Core Activity Team (ACAT) - includes regional and national Student Service managers, and has an annual meeting where issues relating to disabled students can be raised. m) There are a number of mechanisms in place available to students with regard to reasonable adjustments including through Facilities Request Forms (required for support from the OU), the Student Profile and student feedback opportunities as set out in Appendix 2. Students are able to update their profile at any time via StudentHome. n) Course team involvement with Disability Resources Team in audio recording choice, preparation and recording, and other alternative formats. o) Course team involvement with Disability Resources Team in supporting students at residential schools. 7. Consideration of alternatives On the basis of the initial findings set out in Section 5 above, a number of initiatives and actions were identified, some of which arose from this impact assessment, others of which were already underway. The formal consultation (see Section 8 below) on the initial findings and proposed actions has highlighted further important issues. This has enabled additional actions to be identified and prioritised. (see Section 9 Decisions and Actions).

19 8. Formal consultation The draft Disability Impact Assessment report and Summary document were considered in an online conference which ran from 6th April to 23rd April 2010. All OU registered disabled students in the United Kingdom were invited to discuss the draft findings. Responses were invited to consultation questions about the findings, actions and evidence used and personal experiences of studying at the OU. The forum attracted approximately 200 participants. In addition, consultation was undertaken with disabled student representatives on Disabled Student Services working groups, Disabled Student Strategy Advisory Group, as well as with OU Students’ Association representatives. Information about issues raised by disabled students in First Class forum discussions was also provided by one of the student representatives. The feedback highlighted many positive experiences. Students spoke of their enjoyment of study, and the level of support that is available. There were many instances of ‘superb’, ‘brilliant’ and ‘excellent’ being used to describe various aspects of support. However, a number of disabled students who posted complimentary feedback also made further comments on areas for improvement and other students highlighted some very negative experiences where they have felt let down by the University. Access issues raised about the use of OU Moodle for eforum conferences and other issues which are not covered by this impact assessment (such as length of time to complete courses and degrees, more 30 credit courses, variable tutorial support) have been referred to relevant areas. A summary of the main issues raised in this formal consultation is provided in Appendix 4. 9. Decisions and actions 9.1 The feedback from the formal consultation summarised in Section 8 and Appendix 4 has highlighted a number of important issues. Initial actions proposed as part of the impact assessment process have been reviewed as a result of this formal consultation and additional actions determined. Whilst there were concerns that issues have been raised before and things do not appear to have changed, the University does have extensive consultation and involvement mechanisms to listen to disabled students as detailed in Appendix 2. This includes meetings by the Head of Disabled Student Services and the Head of Equality and Diversity with OUSA representatives. Many issues relate to systems changes which take time to put in place in a complex organisation. Although the OU’s Virtual Learning Environment (Moodle) development is not covered by this impact assessment, accessibility issues are regarded as a priority and VLE updates are being regularly arranged and specific access issues raised during the formal consultation were referred to relevant Units. VLE developments undergo quarterly accessibility and usability testing and assessment and recommendations from these reports are taken into account in the subsequent release, or included in future development plans. Supporting and improving accessibility is an important part of the VLE development plan and the assessment that is carried out will continue through future release cycles. The latest versions of OU Moodle forums include many features that are invisible on the screen but support screenreaders in the background. The provision of a ‘non-Java Script view’ in June 2010 has offered an alternative to screenreader users and keyboard users. The new version of the Computing

20 Guide includes some accessibility tips, for example for some users turning off the text editor will improve accessibility. 9.2 A number of individual issues were raised during the formal consultation and via student First Class forums. Whilst these issues are clearly important it is also important to recognise that there are sources of support available to students to deal with individual issues in regional and national centres and with Student Services teams in Milton Keynes. The Student Support Team pilots currently, being undertaken as part of the overall Student Support Review, are addressing aspects relating to streamlining points of contact. A partnership approach to resolving issues is essential between students and the University. The University has a responsibility to be pro-active in making it clear what support services are available and students have a responsibility to be pro-active in seeking information and making their requirements and concerns known.

9.3 A number of issues were raised during the formal consultation about the Disabled Students’ Allowances (DSA) processes. There has been increased publicity on University websites and in student literature to try and ensure that all students are aware of the DSA and processes involved. The DSA office (responsible for students resident in England, Wales and Northern Ireland) is required to follow the guidance and regulations published by the Department for Business, Innovation and Skills with The Open University for the proper disbursement of these government funds. Such guidance includes the period of DSA support, application process, medical evidence required, arrangements for purchase of equipment and requirement for receipts for consumables. The DSA office operates within these parameters and continually improves the quality of its materials to ensure it provides the best customer service it can. The DSA Office is currently updating the application form, trying to reduce its length, and to improve the overall service. The issue of turnaround times is outside the full control of the DSA Office which processes applications as soon as feasibly possible, bearing in mind the timescales involved in Assessors compiling and sending in reports and/ or establishing a convenient time for the student to undertake the assessment. Students can choose their own equipment if they prefer but they then have the responsibility for the maintenance and repair. The DSA Office have long-established relationships with equipment suppliers who understand the needs of DSA-eligible students and who will replace or repair damaged equipment in a timely manner under a service contract. In October 2007 the OU successfully made representation to the Government to allow DSA for students studying 30 credit-point courses (previously 60 credit point minimum) in England, Wales and Northern Ireland. There is also an interim equipment loan scheme available from Disabled Student Services pending the processing of a DSA application and this is publicised in ‘Open to your needs’ which is sent to all students in the registration pack as well as being published on the Services for Disabled Students website. The ‘Meeting your needs’ publication also contains information about the equipment loans scheme.

9.4 The University recognises the impact that delays in receiving alternative-format materials has on students, and is working towards mainstreaming the production of alternative-format course materials through the Securing Greater Accessibility implementation plan. There are, however, systems and investment issues that impact on progress on this implementation plan as well as resource issues which can affect the timescale in providing some alternative format materials. However, Structured Content is becoming the default method of production for OU materials, giving a consistent method

21 of creating and tagging content which allows multiple outputs to be rendered from a single document. Formats currently supported are: PDF, HTML, DAISY, MP3 (synthetic voice), Word, ePub and MOBI. The use of Structured Content provides greater choice and convenience for all students, allowing them to study in different locations using a range of devices and assistive technologies. Student Services literature, websites and other communications with disabled students will continue to emphasise the importance of registering for a course as early as possible and, where appropriate, students may want to register for a course with a later start date, so that support services (such as Disabled Students’ Allowances and alternative formats) can be put in place in as timely a way as is feasible. 9.5 It was stated on the eforum that ‘Many people don’t know they can make a formal complaint, or don’t see it as appropriate in getting the problem solved.’ A website ‘Resolving your concerns, complaints and appeals’ was made available in 2009 and is accessible through the StudentHome website. This website contains comprehensive information about who to contact to resolve problems before making things formal, what the Complaints and Appeals Office can do to help, as well as the facility to make formal complaints online. All student contact with Student Services is recorded on the University’s customer records system (VOICE). 9.6 A number of issues were raised with regard to examinations particularly in terms of alternatives and adaptations. If a course has an examination, this is the course requirement and alternatives to an examination are not approved. In some cases a student can choose a pathway and courses that do not have examinations. Reasonable adjustments for examinations are available, such as additional time and alternative- format question and answer papers, and students can make a case for a home exam. Generalisations about available support, software, permitted materials etc. are not possible as the requirements of each course vary, driven by the learning outcomes of those courses. However, mind mapping tools have also been approved e.g. for some students with dyslexia, and voice-activated software can be used in certain circumstances. The ‘Meeting your Examination Needs’ publication is sent out to all students with a disability or additional requirements marker approximately 3-4 months before their examination, encouraging students to make contact with specialist staff at their regional/national centre to discuss their examination needs as soon as possible. It is already known that the Interrupted Study policy, available currently for a limited number of courses, will assist disabled students when it is more widely available. However, this cannot be expanded until resources can be made available for the necessary systems redevelopment. 9.7 The economic downturn and proposed government cuts in higher education funding as well as the pending adverse effects on the University of ELQ (the government’s decision to stop funding students who are studying for a qualification at an equivalent or lower level), have also to be taken into consideration in determining and prioritising actions. 9.8 The actions set out below should help to address issues raised during the formal consultation on this Impact Assessment Report and should also support improved completion and attainment rates of disabled students.

22 9.8.1 Assessment, Credit and Awards

a) The Examinations and Assessment Section is reviewing the information provided to Examination and Assessment Boards for non examined ECA; and their remit regarding special circumstances where additional arrangements have been made for examinations. b) Changes are being made to the Code of Practice for Student Assessment as it was felt that support for disabled students was not sufficiently covered. c) The next version of ‘Meeting your Examination Needs’ will include additional case studies/examples to illustrate the kinds of reasonable adjustments for examinations that have been made and are available. d) Changes will also be made to the Special Circumstances forms and the information sent to students on how to submit their non-examined end-of-course assessment.

9.8.2 Disabled Student Services a) April 2009 Securing Greater Accessibility (SEGA) Workshop Implementation Plan – this plan supports a continued drive towards mainstreaming the production of course materials in alternative formats. Those Units who will need to support course and programme teams in embedding accessibility of the curriculum have been consulted in order to take forward the recommendations that ensure coherent and consistent accessibility. The draft plan has been endorsed by the Pro-Vice-Chancellor (Learning, Teaching & Quality) and agreement secured from Learning and Teaching Solutions, Institute of Educational Technology, Equality and Diversity Office and the Library. Issues of clarity in course descriptions are being addressed systematically via this SEGA initiative. This will provide accurate and comprehensive information about reasonable adjustments (including alternative formats). b) Disabled Student Services sponsored Implementation Plan is in place to improve support and services for alternative-format course materials and auxiliary aids. As part of this process review, comb binding was fully outsourced in 2009 to improve the efficiency of provision of these materials to students. The next stage is to mainstream the dispatch of the comb-bound materials so that they become part of warehouse stock, ready to be sent alongside the standard mailings. If successful, this will also alleviate the problem as the warehouse would be able to undertake daily sweeps for students and dispatch the materials the next day. The Resources Team can usually only revisit this for a course some time later as work needs to be continued on the dispatch of the first mailings of other courses in the meantime. c) The current decision to limit comb-binding to books of 100 pages or more is a guideline and if feedback tells us that a book of fewer pages is problematic if not comb-bound, the Resources Team will do it immediately for all the students on the course and then add that item to the list so that it is always comb-bound in the future. The page guideline is set at 100 pages because, in most instances, material with fewer pages is usually unsuitable for comb-binding. When identifying new courses to comb-bind (every new course that is produced is assessed), the Resources Team now writes to the relevant course manager for detailed information on the printed items in each mailing. This will help inform decisions about suitability in advance of sending material to students.

23 d) Currently the provision of PDF files and printed transcripts are subject to the same dispatch issues as comb-bound books, i.e. availability of material to process and send, and ability to deal with sweep-up mailings. However, the review of the provision of these services has led to a potential new policy whereby PDF files and transcripts will not be posted to disabled students when those materials are readily available to all students via the main course materials e.g. the VLE or course DVD. Resource will be released which will focus on restricted material (e.g. some co-published books), individual student needs, and the ability to deal with sweep-up mailings better. e) The Resources Team will continue to monitor and ensure students are contacted via their preferred method and that staff are aware of the information on VOICE. f) Disabled Student Services will work with Marketing to consider future projects with regard to the acquisition of disabled students. g) Disabled Student Services will be collaborating with the Equality and Diversity Office to provide a range of case studies of disabled students for the Equality and Diversity Office’s case study website http://www.open.ac.uk/diversitycase studies/index.shtm. These case studies will describe how the support individual students have received has been beneficial to their study journeys and will also highlight important considerations regarding, for example, the provision of study support via DSA and alternative-format course materials. h) The leaflet ‘Open to your needs’ will be reviewed to identify whether further emphasis can be given regarding the provision of alternative-format materials and DSA applications and highlight the availability of equipment for loan from Disabled Student Services to those waiting for their DSA. i) Mental Health Survey 2009 – A project plan sponsored by Disabled Student Services is in development to take forward the significant issues highlighted by the survey. These include addressing the provision of more mental health awareness training for tutors; a strategy to encourage students to disclose a mental health difficulty in order for them to access appropriate study support; and an initiative to share good practice across regions and nations with regard to effective use of student feedback. j) DSS will consider investigating the improvement of completion and attainment of students with different types of disability where the gap is widest. This will focus on students with mental health difficulties and students with specific learning difficulties. k) The Visual Impairment Working Group will include a standing agenda item regarding the VLE and accessibility. l) DSS will proactively liaise with LTS and OUSA to address OU Moodle usability issues using student feedback. m) Continued sharing of good practice across regions, nations and central academic units in light of variations in participation and achievement. n) Consideration will be given to whether information about student needs can be captured earlier during the enquiry process, particularly for those with restricted mobility and multiple disabilities, to improve the effectiveness of support.

24 9.8.3 Postgraduate study The next phase of the postgraduate review will take account of the student feedback from this consultation.

9.8.4 Student enquiries and registration a) Placing an option on the enquiries phone line will be explored for disabled enquirers who wish to discuss support services available. This would route enquiries to regional/national centres b) Clearer information on cut-off dates for course registration in relation to the DSA applications process has been included in the Frequently Asked Questions section of the Open University website. c) The Student Registration & Enquiry Service will investigate the possibility of identifying and analysing student feedback specifically related to disability as part of a wider project to improve use of student feedback in informing business processes.

9.8.5 Disabled Students’ Allowances (DSAs) a) Although students can complete a Disabled Students’ Allowance application online they still have to print it off and send it via the postal system. This is because the student also needs to provide medical evidence confirming their disability and residency. It is possible that in the future, the DSA Office may be able to confirm passport details to confirm residency without the need for students to submit certified copies. However, it will not be possible to authenticate medical evidence in this way, so a full move to an online application is still a long way from fruition. However, the DSA Office is looking into putting the continued funding application online as students do not need to re-submit medical evidence (unless they are requesting a re-assessment) or their residency information. A move to online applications will be considered and implemented when technical resources allow this. b) In line with the drive to increase the uptake of DSAs, students are asked at the point of reservation if they have a disability, mental health condition or specific learning difficulty. If the student declares that they have, then a ‘Meeting Your Needs’ booklet is despatched. In England, Wales and Northern Ireland this includes a DSA application form and a Facilities Request Form 1 (FRF1) – an FRF1 is required for support from the OU. In Scotland students also receive a FRF1 and those who are eligible for a DSA are contacted by the OU in Scotland office. Students are encouraged to apply early due to the length of the process. c) For students whose DSAs are administered by the Disabled Students’ Allowances Office in Milton Keynes, there are web pages contained within the Services to Disabled Students website. A project is underway to review the content and improve the accessibility of the application and claim forms. d) Issues raised about the DSA process during the formal consultation have been referred to the DSA Office for consideration. Additional questions and answers will be considered for the DSA web pages to include issues raised in the feedback not already covered by the current questions and answers. Student Recruitment and Financial Support will continue to review and improve the information it provides to disabled students in written and electronic form in light of the feedback.

25 e) The DSA Office will reinforce with equipment suppliers the need to provide a speedy service to students. f) The DSA Office will review the requirement for claims for certain consumables to be submitted under an agreed limit without receipts. g) The issue about the opportunity of giving disabled students extra DSA ‘time’ to complete their degrees will be raised by the DSA Office with the department for Business, Innovation and Skills and Student Finance England. However, the support offered by a DSA and the extra time students are given to complete assessments and examinations is designed to ensure that disabled students can complete their studies in the same time as students who are not disabled.

9.8.6 Complaints and appeals a) The online mechanism for filing a complaint to The Open University will continue to be made available, and this is currently entitled ‘Resolving your concerns, complaints and appeals’ located at http://www.open.ac.uk/studentservices/complaints/ b) The format of the annual Complaints and Appeals report will quantify complaints from disabled students by:  including totals of complainants and appellants with a disability or additional requirements (DAR) marker;  reporting complaints and appeals from such students at each individual stage. 10. Monitoring arrangements

10.1 Annual equality and diversity report Disabled student data will continue to be collected and analysed annually by the Equality and Diversity Office. The following data will be monitored by disability status:  student participation  completions  attainments  complaints and appeals  student feedback from surveys.

This monitoring and analysis will be reported to Equality, Diversity and Management Group and Disabled Student Strategy Advisory Group and published as part of the Equality and Diversity Annual Report on the Equality and Diversity internet site.

10.2 Unit equality plans Actions in this impact assessment will be integrated into Units’ own equality and diversity planning activities and the more strategic-level actions will be included in the University’s overarching Equality Scheme action plan.

10.3 Central academic units Individual course teams and programme committees will continue to monitor the participation and progress of students by disability status and to take action where issues are identified. Course teams are required to evidence this through approval and reporting

26 processes. Programme Committees report the findings of diversity analysis to the Awards Committees which look at participation and awards.

10.4 Assessment, Credit and Awards Examination and Assessment team reviews take place after each conflation which highlight where policies and procedures are not working well. After each conflation the resulting course result queries are monitored to assess the changes resulting from student communications. Invigilator reports from each examination, including home examinations, are monitored to identify issues relating to disabled students and alternative arrangements made. The Assessment Policy Committee receives an annual report of Examination and Assessment activities and a regular report from the Exceptional Examination Arrangements and Special Circumstances Sub-Committee (EEASCS) on their activities, many of which concern disabled students. The annual meeting of the Assessment Core Activity Team (where representatives from the regions/nations and Walton Hall come together) offers the opportunity to monitor the operation of assessment policies and procedures. The Assessment Operations Group meets regularly to discuss and review assessment procedure and is a vehicle for the consideration of disability-related issues. The Awards Committee monitors the implementation of award policy and receives an annual report on credit transfer and award completions. 11. Publishing This report will be published internally on the Disabled Student Services intranet site and externally on the University’s Equality and Diversity website: http://www.open.ac.uk/equality-diversity . 12. Next review The monitoring arrangements set out in Section 10 above, and the feedback mechanisms detailed in Appendix 2 will enable us to evaluate progress made in addressing the issues identified in this Disability Equality Impact Assessment and to determine whether any further impact assessment or other actions are necessary.

27 Appendix 1

Open to your needs

“I would say to anybody, do it… with the OU it’s possible!” Ian Holloway, Open University student

This leaflet summarises the support services and facilities that are available for students of The Open University who have a disability, health condition, mental-health disability or specific learning difficulty (such as dyslexia) that affects their ability to study, attend a residential school or take examinations.

An audio CD, Braille or electronic version can be made available. Please contact the Disabled Student Services Resources Team (contact details are at the end of this leaflet). It is also available online at www.open.ac.uk/disability Our commitment to you Over 10,000 people with disabilities study with us each year. Our mission is to be ‘open to people, places, methods and ideas’. Most of our courses don’t have entry requirements and, wherever we can we will provide additional support for students to enable them to take part in every aspect of university life. The Open University’s Disability Equality Scheme and Action Plan which is now incorporated within our Single Equality Scheme sets out our policy and commitment, and is available on our website at www.open.ac.uk/our-student-policies Why choose The Open University? We offer a wide range of courses from introductory to postgraduate level, and the study materials are carefully written to provide support throughout your learning. Support is also available from a tutor. We can help put arrangements in place to meet additional requirements you may have in connection with your disability. Where can I get advice? We want to help you make the right choices. If you need help with choosing courses or advice about study arrangements, tutorial support or financial support, or have any other enquiry about studying with us, please contact the Student Registration & Enquiry Service (contact details are at the end of this leaflet). What support can I expect?

Disabled Students’ Allowance A Disabled Students’ Allowance (DSA) is a government grant that can help with the extra costs of studying arising from a disability or specific learning difficulty. It is not means- tested (not based on financial circumstances) and there is no age limit for eligibility. You may be eligible for a DSA if:

28  you have a mental-health condition;  you have a specific learning difficulty (such as dyslexia);  you have a physical disability;  you have a medical condition which affects your ability to study;  you are deaf or hard of hearing; or  you are blind or partially sighted.

You must also meet the following conditions.  You must live in the UK.  You must be registered to study at least 30 credit points (60 if you live in Scotland).  You must be working towards an OU qualification.

We will send you information explaining how to apply when you contact us or register for a course, or courses, worth 30 points or more and tell us about your disability or other specific needs.

A DSA can open the door to a wide range of assistive technologies (specialist equipment to help you to study effectively), and can pay for study-related help such as a notetaker or interpreter for tutorials. The level of support available may differ depending on where you live. It will also pay for a needs assessment that will help you, along with a trained expert, to work out exactly what you need to help you with your studies.

The Open University will only provide study support that cannot be provided by the DSA. If you require disability-related support for your studies you should apply for a DSA.

You can find out more information on our website at www.open.ac.uk/disability. Other financial support As well as the Disabled Students’ Allowance, you may be eligible for other financial support or you may qualify for help towards the cost of course fees and study expenses. You can get more information by visiting our website at www.open.ac.uk/financialsupport or by phoning the Student Registration & Enquiry Service. Tutorials The type of tutorial support we provide depends on your course, how many other students there are in your group and where they all live. It can include face-to-face group meetings or tutorials by phone or online forums. Tutorials are an optional but valuable part of many OU courses.

29 We can arrange for you to have sign-language interpreters, lip speakers, notetakers and so on at tutorials. We may also be able to provide you with assistive equipment (explained below). Extra tuition may be available if you are experiencing difficulties with your course or if you can’t go to a tutorial. Study materials Many of our study materials are available in accessible formats. We have audio recordings and electronic versions of many of our course texts and set books, and transcripts of DVDs and audio CDs. We can also supply many course texts in large print or with spiral binding (to make them easier to handle) if you ask us. Assistive equipment If you are not eligible for a DSA, we may still be able to help you from the wide range of assistive equipment we have available – including computers with assistive software, digital voice recorders, talking calculators, audio players, DAISY players and portable magnifiers. We can arrange for you to have a needs assessment and lend you the equipment free of charge for the period of your study. If you just need small items, a discussion with us may be enough. Residential schools If your course has a residential school, we can help you to access our booklet Meeting your needs at residential school. We will ask you to tell us about the services and facilities you may need us to provide. More information is available on our website at www.open.ac.uk/residential-schools. Examinations and assessments We try to adjust arrangements to suit individual needs so that all students can be assessed on the same basis. For example, if your course has an examination, we may arrange for you to have extra time, rest breaks or to take your examination at home. We can provide question papers in alternative formats (Braille, audio recording, large print or special colours) and you may be allowed to present your answers in different ways, for example, Braille, audio recording, computer disk, or by dictating to an ‘amanuensis’ (scribe). Careers service We can help you to match courses to your career ideas, discuss career plans with you, help you to complete applications and CVs, prepare for interviews and look for employment, as well as helping you to consider further study or professional training. You can find out more by visiting our website at www.open.ac.uk/careers or by contacting our Student Registration & Enquiry Service. You can also ask for our publication OU study and your Career or view it on our website. Telling us about your requirements When you apply or register for a course with us, we will ask if you have a disability or additional requirement that might affect your studies. If you answer ‘yes’, we’ll send you

30 our booklet Meeting your needs, which gives more detailed information about the services and support we provide.

We’ll ask you to complete a Facilities Request Form to tell us about your disability and study requirements, and will use the information to help us make additional support arrangements for you.

If you are studying 30 credit points or more (60 if you live in Scotland), we’ll ask you to fill in a DSA application form as well.

Please be aware that it may take us several months to provide some additional services and facilities. Please register as early as possible so that they can be ready for you in good time. Confidentiality We will treat all the information you give to us and to the DSA office as confidential and will use it only to provide you with services and facilities as a student.

So that we can help you make the most of your studies, please tell us about any additional requirements you may have in connection with your disability, health condition, mental- health disability or specific learning difficulty (such as dyslexia). If you do not let us know, we may not be able to support you effectively or provide you with the services described in this leaflet. Please let us know as soon as possible and ideally when you first apply or register with us.

Please note that you may apply for a Disabled Students’ Allowance without telling us about your disability or specific learning difficulty. However, in these circumstances, you will not automatically receive an application form, but will need to contact the DSA office direct to ask for one. If you live outside the UK There are some services we can’t provide for disabled students outside the UK. For example, we may not be able to provide you with a sign-language interpreter or lend you a computer if you live outside the UK, although we will do our best to support you in other ways.

Please contact us to discuss your individual circumstances. Your comments The Open University is always interested in improving its services to disabled students. If you’re unhappy with a particular service – or if you feel you’ve had particularly good service – please tell us.

31 Contact information

Advice about study in the UK and for British Forces Post Office (BFPO) addresses outside the UK

Student Registration & Enquiry Service Phone: +44 (0)845 300 60 90

Our lines are open:  Monday to Friday 08.00–20.00 (UK time); and  Saturday 09.00–17.00

Calls to this line are charged at the UK local rate when calling from a UK landline.

Wales/ Y Brifysgol Agored yng Nghymru Phone: 029 2047 1170 Email: [email protected]

If you would prefer to discuss your study needs in Welsh, you are welcome to contact The Open University in Wales in Cardiff.

Os yw hi’n well gennych drafod eich anghenion astudio yn Gymraeg mae croesco i chi gysylltu â’r Brifysgol Agored yng Nghymru yng Nghaerdydd. Advice about study outside the UK

The Open University in Ireland Phone: 028 9024 5025 (From the Republic of Ireland) 048 9024 5025 Email: [email protected]

For other countries Phone your country representative. Phone: +44 (0)191 477 6104 Email: [email protected] (The Open University in the North) Other useful contact information

Disabled Student Services Resources Team Phone: 01908 653745 Email: [email protected] Textphone: 01908 655978 Fax: 01908 655547

32 Disabled Students’ Allowance Offices Phone: 01908 654136 Email: [email protected] Textphone: 01908 659955 Fax: 01908 659956

For students in Scotland Phone: 0131 226 3851 Email: [email protected] Fax: 0131 220 6730 Websites www.open.ac.uk/disability www.open.ac.uk/our-student-policies www.open.ac.uk/residential-schools www.open.ac.uk/study www.open.ac.uk/careers www.open.ac.uk/financialsupport Disclaimer Although we will do all we can to provide you with services that meet your requirements so that you can study our courses successfully, we cannot guarantee this. We will give you as much notice as we can of any limit on our services.

We may record our phone calls with you to make sure that we have carried out your instructions correctly and to help us improve our services through staff training.

This publication was prepared by Disabled Student Services and produced by the Student Services Communications Team. While we have done everything possible to make sure the information is accurate, the information may change in the light of altered regulations or policy, or because of financial or other restrictions.

The Open University is incorporated by Royal Charter (RC 000391), an exempt charity in England & Wales and a charity registered in Scotland (SC 038302)

The Open University Student Services

Updated December 2009 SUP 019163

33 Appendix 2

Disability Impact Assessment - Summary of data, evidence and other sources of feedback

External benchmarks

 The OU Access Centre is a major provider of home-based and remote Disabled Students’ Allowance assessments and assessed over 1,800 (OU and non-OU) students in 2008-2009. It manages a network of external DSA assessors covering most of England, Wales and Northern Ireland. In line with government policy the OU Access Centre is audited annually by the independent external auditors, DSA Quality Assurance Group (DSA-QAG).  Equality Challenge Unit’s ‘Equality in Higher Education - Statistical Report 2009.  National Student Survey of Higher Education Institutions.  DSA-QAG (the Disabled Students Allowance Quality Assurance Group) - a stakeholder-led organisation provides a quality assurance service for assessment centres and suppliers involved in the delivery of the Disabled Students' Allowance scheme in England and Wales. They measure the quality of the work of organisations conducting DSA needs assessments and supplying the recommended DSA equipment. DSA-QAG launched an online survey on 26/11/09 to students in receipt of DSA in order to get their views and experiences of the service(s) provided by the Assessment Centres and Suppliers. The questionnaire invites them to participate in rating the services provided to them at three key stages in the DSA process, i.e. the assessment, the delivery of the equipment, and ongoing support throughout their course. DSA-QAG will provide feedback to relevant University working groups on the results, for example, the National Network of Assessment Centres (NNAC), the National Association of Disability Practitioners (NADP), Student Finance England, and OU DSA Office, among others. It has yet to be decided whether this will be monthly, quarterly or six monthly. Any significant issues identified will be addressed as appropriate. Internal data The following student data analysed by disability status has been used for this assessment:

 Participation: undergraduate and postgraduate students 2003/4 to 2007/08 by new and continuing, age, gender, ethnic group, region, central academic unit, types of disability.  Provisional registration headcount breakdowns for 2008/9.

34  FTE completion breakdowns: undergraduate and postgraduate students 2003/4 to 2007/08 by new and continuing, age, gender, ethnic group, region, central academic unit, type of disability.  Academic attainment: UK undergraduate and postgraduate students 2003/4 to 2007/08.  Management information from ADAR, the redeveloped Additional Exam arrangements database.  2008/9 Alternative-format exam question and answer papers.  Analysis of official examinations and assessment complaints for disabled students from 6 regions during the period 1/4/09 - 1/9/09.  Analysis of sample special circumstances forms June 2009.  Data on the number of new DSA applications received; new awards made and continued funding applications received.  Article: ‘Course completion and attainment in disabled students taking courses with the UK Open University’ by John T.E. Richardson - currently in press.  Alternative-format registration-related communications 2009.  Registration methods used by students declaring a disability or additional need 2008/09.  Student complaints and appeals 2008 and 2009.  May 2009 Early Course Experience Survey: DSS requests quantitative and qualitative data output from this survey to monitor areas where disabled students at an early point in the course may require more support.  November 2008 Course Experience Survey (sponsored by DSS): contains feedback from disabled and non-disabled students regarding IT and a range of study support facilities and services.  Autumn 2008 Courses Survey: there are specific questions pertaining to disability and satisfaction levels in this Survey, and the opportunity for open text comments which are analysed for issues that can be followed up or indicate trends.  2008 Withdrawal Survey: data is monitored in regional/national centres. Open text anonymised comments from disabled students who have responded are disseminated by DSS to relevant offices for consideration and action as necessary.  Learning, Teaching and Student Support Committee Course Completion 2008/09. Other sources of feedback  Equality and Diversity Annual report 2008 containing feedback from disabled student consultation on progress on Disability Equality Scheme.  OU Students’ Association meetings held with Head of Equality and Diversity and Head of Disabled Student Services. Key staff are invited to report on specific issues.

35  2008 Residential Schools' feedback forms for disabled students: disabled students who have requested assistance at residential school are invited to feed back on their experience annually. Comments are considered for improving the service where necessary.  DSS website (http://www.open.ac.uk/disability/): a feedback mechanism invites comments which are monitored and followed up as necessary.  2008 Equipment loan feedback: conducted via telephone by DSS with comments logged on Voice in order to improve systems and processes.  2008 Audio users’ feedback questionnaire: sent with mailing of alternative format course material in audio format. Feedback is recorded on VOICE and used to improve the service.  2009 survey of disabled students with mental health issues contains feedback regarding a range of support currently provided and its effectiveness.  Three e-forums in 2009: ‘Organising yourself for study’, ‘Disabled Students’ Allowance’ and ‘Assistive Technology’ specifically targeted at disabled students.  Compliments log: DSS records positive student feedback for support and service  Emails via the ‘contact us’ link on Student Home and comments on the special circumstances forms which are reviewed by the regions and nations.  Summary of responses to OU Equality Scheme Consultation October–November 2009

36 Appendix 4

Summary of feedback from the formal consultation with disabled students 1. Alternative format materials This subject caused most discussion on the eforum. A number of students stated they do not receive their required format materials until well into the start of the course despite having registered months before the start. Late arrival of comb-bound books was a prime concern and some students mentioned late arrival of printed transcripts for DVDs and CDs. Students don’t understand why this is happening, some believing it is simply a matter of lack of understanding on the part of staff as to why alternative formats are central to their study. The lack of availability of comb-binding for books under 100 pages was also raised and some students have stated that alternative formats provided are not appropriate for their needs. The unsuitability of some pdf files for screen readers was also raised. Students want alternative-format materials to arrive at the same as other students receive their materials and prior to course start. 2. Disabled Students’ Allowance (DSA) Feedback on DSA matters was also high. A range of very positive comments were made about the DSA office staff and DSA assessments. However, concerns were raised by a number of students about the complexity of paperwork, not being able to comply with the required minimum of 30 credit points (60 credit points in Scotland) and the 6-year rule. A number of students stated that it takes many disabled students much longer than 6 years to complete their degree and this timescale is unrealistic and even discriminatory. With regard to credit points many students state they are unable to study longer courses but feel they should be given support nonetheless. Other students had not been aware of DSA so had not applied from the start. Those who do apply are generally pleased with the needs assessment process and the equipment they are awarded. However, many students expressed discontent with the time taken to complete the DSA process and for support to be put in place (in spite of applying in good time). DSA Assessors have been praised throughout, students generally appearing to be satisfied with this aspect of the process. There was also a fair amount of discussion regarding having equipment ordered or being able to choose your own. – there were very mixed views here. Concerns were also raised about the time taken to arrange equipment repairs/replacements, and lack of training on use of new equipment. Claiming for consumables is also problematic and a number of students stated that they don’t use this allowance due to having to organise receipts to be sent in, complete more forms and wait for several weeks for a refund which can be hard due to limited cash flow. Having to pay for medical evidence, and being repeatedly asked for more, were also raised as issues. The difficulty of tracking down correct information about support queries, and being told different things by different departments, was also mentioned by some students, and that due to the quantity of students who apply, even with early application, there can still be a delay in receiving an assessment. Some students felt the OU should be doing more to lobby the government

37 that the current regulations fail to reflect the patterns of study followed by many disabled students. 3. Exams The main issue raised was that many students feel exam results do not reflect true ability and would like an alternative e.g. end-of-course assessment (ECA) to be provided for more courses. Some students felt they should not be restricted to taking courses without an exam which affects whether they can gain an open or subject-specific degree. Despite extra exam time being made available to many students, some stated that this does not help their memory. There was some concern about the ‘closed book’ exam policy and that the needs of dyslexic students and those with memory difficulties are not being met. It was suggested that the interrupted study facility should be extended to all 60 credit- point courses. 4. Other issues raised include:  More accessibility information needed on course descriptions and more information for disabled students at point of enquiry.  There were mixed comments about support for mental health but in general students would like to see more understanding.  Concerns about limited funding and support available for postgraduate study.  Difficulty some students have knowing who to contact.  A few students not knowing what help is available and stating that it is not made clear at enquiry stage.  A view that the reason there are low numbers of formal complaints about disability-related issues is because it is stressful to make complaints. Some students don’t know where or how to make complaints and some don’t complain because of fear that it will affect their studies.  These kinds of issues have been discussed on various forums and via OUSA but things do not appear to change.  E-books being cumbersome and unwieldy for some students.  Disturbed by the reduction in grades achieved on Level 2 and 3 courses.  Failure to contact some students in their preferred method.