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SLC impact assessment on changes to DSA eligibility, and the current protocols and procedures for assessing DSA eligibility

Amanda Kent made this Freedom of Information request to Student Loans Company Limited

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

We're waiting for Amanda Kent to read recent responses and update the status.

Dear Student Loans Company Limited,

I would like to see information that you hold on:
1. Equality Analysis (Impact Assessment) conducted by the SLC in relation to the change of evidence criteria for disability required by the SLC when determining eligibility for Disabled Students Allowance as outlined in the DSA Guidance chapter 14/15 issued February 2014.
2. The SLC protocols and procedures for determining whether the medical evidence submitted by DSA applicants is sufficient to conclude that the student falls within the Equality Act definition of disability.

Context:
Availability of information
http://www.slc.co.uk/media/282788/equali...
http://www.slc.co.uk/media/787884/equali...
Student Loan Company Equality Objectives 2012/13 page 16 refer to plans to develop and then to publish aspects of Equality Analysis (Impact Assessment) work and the Equality Objective update March 2014 page 9 indicates this work is ongoing . A previous Freedom of Information Act request regarding the impact assessment on an aspect of DSA processing has been successful (see SLC ref 170/12). This suggests that Equality Analysis documentation for other aspects DSA process change should be readily available on request.
Transparency on changes to eligibility criteria for DSA applicants and their advisers
In the recent past, the DSA Guidance chapter has stated “The Regulations do not define disability, but all cases where extra costs are incurred in studying because of a disability (including a long-term health condition, mental health condition or specific learning difficulty such as dyslexia) should be considered.” (13/14 para 3). The 14/15 DSA Guidance chapter still states that the student support regulations do not define disability and this may reflect the fact that the relevant Statutory Instrument has yet to be passed. Nevertheless, the Equality Act definition of disability has added to the DSA Guidance and page 9 of the SLC March 2014 Equality update referenced above shows that this addition was made by BIS. This FoI request is not seeking the BIS impact assessment, nor does it seek documents held by BIS in relation to the plans for DSA modernisation announced by the Minister on 7th April 2014. Rather, the information sought relates only to the change in process in the administration of the DSAs at SLC with regard to evidence of disability. The assumption is that it would have been reasonable to assume that the administration of this change may have an impact on disabled people and therefore an Equality Analysis on the application process and the SLCs internal handling of the resultant applications would have been the subject of impact assessment.

Yours faithfully,
Amanda Kent

FOI Publication Scheme, Student Loans Company Limited

Dear Ms Kent

Thank you for your email dated 29/06/2014 requesting information under the
Freedom of Information Act 2000. Your request has been logged under
reference 127-14. Please quote this reference in future communications.

A full response will be issued in due course.

Yours sincerely

Louise Chapman
Legal Executive
Student Loans Company Limited
100 Bothwell Street
Glasgow
G2 7JD

Tel: 0141 243 3062 (ext 33062)

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FOI Publication Scheme, Student Loans Company Limited

Dear Ms Kent

I refer to your email dated requesting the following information under the
Freedom of Information Act 2000 (“FOIA”):

“1. Equality Analysis (Impact Assessment) conducted by the SLC in relation
to the change of evidence criteria for disability required by the SLC when
determining eligibility for Disabled Students Allowance as outlined in the
DSA Guidance chapter 14/15 issued February 2014.

2. The SLC protocols and procedures for determining whether the medical
evidence submitted by DSA applicants is sufficient to conclude that the
student falls within the Equality Act definition of disability.”

Response

Having conducted a search of our records, I can confirm that the Student
Loans Company Limited (“SLC”) does hold some information that falls within
the scope of your request.

In response to question 1, the change of evidence criteria was instructed
by the Department for Business, Innovation and Skills (“BIS”), therefore
SLC has not conducted any Equality Impact Assessment. This question could
be redirected to BIS at [email address]

In response to question 2, in order to determine whether medical evidence
submitted is sufficient to conclude that a student falls within the
Equality Act definition, it should confirm that the disability has a
substantial and long term adverse effect on their ability to carry out
normal day-to-day activities. If the submitted medical evidence does not
confirm this, then a student will be asked for further evidence by way of
clarification. I would refer to you to information that is already in the
public domain:

http://www.slc.co.uk/stakeholders-partne...

http://www.practitioners.slc.co.uk/media...

Internal review process

I trust that my answer to you is satisfactory; however, if you are unhappy
with the decisions made by me in relation to your freedom of information
request, you may ask SLC for an internal review.

Any such appeal would be conducted by John Brown, Company Secretary, 100
Bothwell Street, Glasgow, G2 7JD. You may request a review by writing to
John Brown or by emailing the FOI Office
([SLC request email]). SLC will only consider requests for
internal reviews which are made within 3 months of the date of our original
response (except in exceptional circumstances).

If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a decision.
The Information Commissioner can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Please note that freedom of information responses may be published on our
corporate website www.slc.co.uk under the Freedom of Information disclosure
pages
(
http://www.slc.co.uk/freedom-of-informat...
).

Yours sincerely

Louise Chapman
Legal Executive
Student Loans Company Limited
100 Bothwell Street
Glasgow
G2 7JD

Tel: 0141 243 3062 (ext 33062)


Amanda Kent
<request-218230-7
c8271cf@whatdothe To
yknow.com> FOI requests at SLC
<[SLC request email]>
29/06/2014 08:27 cc

Subject
Freedom of Information request -
SLC impact assessment on changes to
DSA eligibility, and the current
protocols and procedures for
assessing DSA eligibility





Dear Student Loans Company Limited,

I would like to see information that you hold on:
1. Equality Analysis (Impact Assessment) conducted by the SLC in
relation to the change of evidence criteria for disability required by the
SLC when determining eligibility for Disabled Students Allowance as
outlined in the DSA Guidance chapter 14/15 issued February 2014.
2. The SLC protocols and procedures for determining whether the
medical evidence submitted by DSA applicants is sufficient to conclude that
the student falls within the Equality Act definition of disability.

Context:
Availability of information
http://www.slc.co.uk/media/282788/equali...
http://www.slc.co.uk/media/787884/equali...

Student Loan Company Equality Objectives 2012/13 page 16 refer to plans to
develop and then to publish aspects of Equality Analysis (Impact
Assessment) work and the Equality Objective update March 2014 page 9
indicates this work is ongoing . A previous Freedom of Information Act
request regarding the impact assessment on an aspect of DSA processing has
been successful (see SLC ref 170/12). This suggests that Equality Analysis
documentation for other aspects DSA process change should be readily
available on request.
Transparency on changes to eligibility criteria for DSA applicants and
their advisers
In the recent past, the DSA Guidance chapter has stated “The Regulations do
not define disability, but all cases where extra costs are incurred in
studying because of a disability (including a long-term health condition,
mental health condition or specific learning difficulty such as dyslexia)
should be considered.” (13/14 para 3). The 14/15 DSA Guidance chapter still
states that the student support regulations do not define disability and
this may reflect the fact that the relevant Statutory Instrument has yet to
be passed. Nevertheless, the Equality Act definition of disability has
added to the DSA Guidance and page 9 of the SLC March 2014 Equality update
referenced above shows that this addition was made by BIS. This FoI request
is not seeking the BIS impact assessment, nor does it seek documents held
by BIS in relation to the plans for DSA modernisation announced by the
Minister on 7th April 2014. Rather, the information sought relates only to
the change in process in the administration of the DSAs at SLC with regard
to evidence of disability. The assumption is that it would have been
reasonable to assume that the administration of this change may have an
impact on disabled people and therefore an Equality Analysis on the
application process and the SLCs internal handling of the resultant
applications would have been the subject of impact assessment.

Yours faithfully,
Amanda Kent

-------------------------------------------------------------------

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Dear FOI Publication Scheme,

As directed I will request from BIS the equality analysis on the change to DSA eligibility evidence as set out in the DSA Guidance released in Feburary 2014.

With regard to question 2, I am aware of the information in the public domain. My intention was to use the FoI process to reveal information that the SLC holds that is not in the public domain. Perhaps I was unclear about that, so I will restate: I request that another check is done with the relevant DSA administrative team for more detailed information held at the SLC but which can be released under the terms of FOI with regard to processes, checks, decision matrix or flowchart guides, and internal quality checklists or guides used to determine whether the medical evidence sent by a DSA applicant meets the evidence requirements set out in the DSA Guidance.

Yours sincerely,

Amanda Kent

FOI Publication Scheme, Student Loans Company Limited

Dear Ms Kent

Your email has been forwarded to our Company Secretary John Brown to
review. Your internal review has been allocated reference IR03-14.

Mr Brown will aim to respond within 20 working days of your request for an
internal review, calculated to be 01/09/2014.

Yours sincerely

Louise Chapman
Legal Executive
Student Loans Company Limited
100 Bothwell Street
Glasgow
G2 7JD

Tel: 0141 243 3062 (ext 33062)

show quoted sections

FOI Publication Scheme, Student Loans Company Limited

Dear Ms Kent

Further to your recent request for an internal review of my decision dated
29/07/2014, I am emailing to advise that our Company Secretary, John Brown,
is currently on annual leave, and whilst he has been made aware of your
request for an internal review he has not yet had the opportunity to review
the original decision. There are no statutory timescales for internal
reviews as with freedom of information requests, however in line with
Information Commissioner guidance, we aim to respond to requests for
internal reviews within 20 working days. I have calculated the internal
review response to be issued no later than Monday 01/09/2014. Mr Brown is
due to return from annual leave on this date, but may not have the
opportunity to review the original decision in time, therefore I wanted to
ask if you would accept an alternative reviewer in his absence, or if you
would accept a short delay in the response being issued (if this is
necessary). I would propose an alternative reviewer of our Company
Solicitor.

I look forward to hearing from you.

Regards

Louise Chapman
Legal Executive
Student Loans Company Limited
100 Bothwell Street
Glasgow
G2 7JD

Tel: 0141 243 3062 (ext 33062)

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FOI Publication Scheme, Student Loans Company Limited

2 Attachments

Dear Ms Kent

Please find attached the decision of our company Secretary, John Brown,
following consideration of your request for an internal review.

Yours sincerely

Louise Chapman
Legal Executive
Student Loans Company Limited
100 Bothwell Street
Glasgow
G2 7JD

Tel: 0141 243 3062 (ext 33062)

(See attached file: Internal review decision 01.09.14.pdf)(See attached
file: Extracts from DSA Matrix v0.1.pdf)

show quoted sections

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