In its response to the consultation by the Higher Education Funding Council for England, which ends today, the Russell Group says it is unconvinced about the merits of introducing a system of post-qualification applications (PQA) by 2016.

It is understood that Mary Curnock Cook, chief executive of Universities and Colleges Admission Service, set out proposals for a move to PQA at a closed meeting at the Universities UK annual conference earlier this month.

But the possible admissions overhaul is questioned by the Russell Group, which says that ¡°major changes¡­must be shown to offer significant benefits to the majority of applicants¡±.

¡°We would need to be persuaded that the potential benefits of PQA outweigh the disadvantages for students as well as the costs and major upheaval involved for both schools and universities,¡± it says.

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¡°Any changes to the current system should not restrict the ability of institutions to make a fair and thorough assessment of applicants or that of applicants to make informed decisions about which university to apply to.

¡°We would particularly need to be persuaded that changes to the system will not hamper our efforts to attract students from disadvantaged backgrounds.¡±

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Advocates of PQA say that many students do not apply to the most selective universities because they believe they will not secure the necessary grades. When they receive high grades, they realize they could have aimed higher.

However, critics say it leaves universities little time to select students, while applicants have a shorter period to choose where they will study.

It would also see exams brought forward six weeks, with students receiving their results in early July, rather than August.

The Russell Group, which represents 20 large research intensive universities, also outlines its opposition to proposed early repayment penalties on student loans, which are designed to stop richer students from paying less over time than poorer students.

¡°We recognise the merits of ensuring that all graduates make a fair overall contribution to the costs of their higher education and that that contribution should take income into account,¡± it says.

¡°However, we think that the government should not impose an additional penalty on those who want to repay early.¡±

With the Hefce teaching budget set to fall by ?2.9 billion to ?2 billion by 2014-15, it also calls for the government to concentrate state spending on high-cost subjects, such as science and engineering.

And it raises concerns over the student number control system, which will free institutions to compete for unlimited numbers of students with grades of AAB or better at A level, once these students are deducted from their core quotas.

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Wendy Piatt, director general of the Russell Group, said: ¡°We recognise that the high cost of the student support package requires some controls on student numbers and believe that maintaining quality is more important than increasing overall student numbers.¡±

She also voiced concerns over interference by the Office for Fair Access, which will monitor the number of students from poor families admitted to universities.

¡°We remain concerned that the government¡¯s proposals on access risk focusing too much on regulation rather than resolving the real problems: underachievement at school and poor advice on the best choices of A-level subjects and degree courses,¡± Dr Piatt said.

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However, the group welcomes plans for a ¡°risk-based¡± quality assurance scheme, in which some institutions would be exempted from regular checks by the Quality Assurance Agency.

Meanwhile, the 1994 Group of smaller research intensive universities uses its response to the consultation to argue that plans to lift the recruitment cap on students with grades higher than AAB at A-level, and to allocate more places for institutions charging fees lower than ?7,500, ¡°may not create the responsive, demand led market¡±.

Paul Wellings, chairman of the group and vice-chancellor of Lancaster University, said: ¡°We fully support the government¡¯s desire for a system geared towards student expectations, where excellent institutions are able to expand to meet high demand.

¡°However, the proposals currently on the table don¡¯t go far enough. They will only allow extra places for a few students, and mean that many others will be denied a place at an outstanding institution. The government needs to rapidly expand the proposals if it wants to see real competition and choice for students.¡±

Andy Westwood, chief executive of GuildHE, added that specialist institutions, such as art and drama schools, could be disproportionately penalised under the new system.

¡°Many of the government¡¯s proposals run the risk of damaging key parts of the higher education landscape when local economies, public services and key sectors need it the most,¡± he said.

And Janet Beer, chair of the University Alliance, argued that the proposals could result in fewer places on ¡°high-demand, high-quality courses with good employment outcomes in the mainstream of the sector¡±.

¡°We are concerned that this won¡¯t lead to a demand led system. We therefore strongly support Hefce and the government¡¯s commitment to monitor the situation and make any necessary changes in 2013-14,¡± she said.

¡°It is not the case the removal of numbers from one part of the sector and replacing them at another will cater for the same set of students or deliver the same outcomes.¡±

Pam Tatlow, chief executive of Million+, called for the government to withdraw the AAB and sub-?7,500 proposals or at least delay their implementation until 2013-14.

¡°It is too tight a timetable to implement¡±, she said. ¡°The government needs to take these plans off the table and start again¡±.

She criticized the ¡°removal of taxpayer funding from more socially inclusive universities¡± and the transfer of resources to more elite universities via the student loan system.

In its submission to Hefce, Million+ states the plans ¡°may not¡­promote higher quality teaching, particularly as the White Paper lacks a direct and specific focus on supporting excellence in teaching and learning.¡±

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It adds: ¡°Unrestricted recruitment of ¡®high achieving¡¯ AAB+ students creates a perversity in the market which has the effect of privileging choice for a sub-section of students at the expense of others.¡±

jack.grove@tsleducation.com