Four points actually

 The lobby, “supports the need for the package overall,” but proposes variations to the bill.

* a budget neutral change to costs for students for courses. The IRU proposes reducing the highest charges to the maximum that now applies and increasing the planned lowest course costs to make up the shortfall

* making the amount per student place government now provides universities a base for university funding. “Universities should not receive less per student on average than they currently do.”

* increasing funded places, “the number planned will only just cover the population growth in the younger age groups in the short term and will fall well short towards the end of the decade.”

And then there are the issues that really exercise the IRU, the “additional accountability requirements with no justification,” in Schedule Five, notably students must pass 50 per cent of subjects to access FEE_HELP.

“This is a major extension of regulation over universities, with a limited evidence base for the need,” IRU warns