Education, training and workforce planning - Health Committee Contents

4  Funding education and training

The proposed tariff

162.  As we have already observed, the current arrangements for funding education and training in the NHS are widely seen as lacking in transparency and accountability—with unfairness in how funds are allocated and too little focus on quality and value for money. The proposed response to this is the development of a tariff system, whereby "the money follows the student", instead of providers receiving a block grant; and a requirement on providers to account for the service they provide.

163.  In Developing the Healthcare Workforce (December 2010) the Government stated its commitment "to the principle of tariffs for education and training as the foundation to a transparent funding regime that provides genuine incentives within the health sector and minimises transaction costs".[240] Accordingly, HEE would be made responsible for benchmark pricing in respect of HEE-funded education;[241] and a tariff-based approach would be adopted to funding for all clinical placements (medical and non-medical), as well as postgraduate medical education and training.[242]

164.  Given the substantial financial impact that this would have for the funding of some providers, implementation of tariffs would take place over time to avoid destabilising any provider and allow adjustment to the new arrangements. Options for managing the transition from 2012-13 would be discussed with providers and SHAs.[243] The proposed tariffs would be based on "a detailed costing exercise […] undertaken with a sample of providers". In the longer term, the DH aspired to tariffs based on "the cost of education and training, net of any service contribution", which would avoid cross-subsidisation of service provision from education and training funds, ensuring that the money followed the student more effectively.[244]

165.  In evidence that we received in autumn 2011 we heard that there was widespread support for the principle of funding reform. Professor Sowden, of COPMeD, told us that the current arrangements were:

opaque and through a glass darkly for almost everyone in the system. You cannot properly explain to anybody exactly how money flows right to the end point, which is the delivery of education and training for the student or trainee. That is not an acceptable position. The aspiration to have a tariff based system is absolutely right and proper […] it will take some time to achieve, but it will be worth the effort.[245]

166.  Other witnesses agreed that, while the challenges involved in constructing more transparent arrangements should not be underestimated, they were not insurmountable. Professor Edwards, of MEE, told us that there was a potential model in the work of the NIHR in unravelling a hitherto "totally opaque" system for funding research:

No one really knew where it was going or how it was being used. What they did on day one was to take the money away. They took it away, gave it back for a three year period and then produced a very clear plan. It is going to take quite a long time to work it out.

There was also the example of the work done by NHS Education for Scotland on the Additional Cost of Teaching fund (through which clinical placements for medical students are funded—equivalent to the Service Increment for Teaching in England):

They took four years to have a dialogue with people locally as to how the money was being used and how it could better be used, and so on. They have now come up with a really sensible way in which that money is being properly allocated. You cannot change things overnight. You will destabilise not only teaching and training but also the delivery of healthcare. We have to be very careful, but it is possible to do it if you have that sort of approach.[246]

167.  We were told in some submissions that non-medical clinical placements were "currently reliant on good will, professional responsibility and subsidised funding from other areas within service provider organisations".[247] However, the introduction of a dedicated tariff for this purpose could have the perverse effect of causing providers to opt out of providing non-medical placements in favour of providing medical placements. This would be due to the tariff for the latter being so much greater than that in respect of the former.[248]

168.  Other evidence we received raised concerns that the tariff would be based too narrowly on the cost of training and would not "take account of the wider potential costs to services of providing training". This could leave some providers at a significant disadvantage, "especially in an environment where healthcare providers are competing with one another" (as the Government intends in the NHS).[249] Birmingham Children's Hospital FT was concerned about the potential impact of tariffs on specialist providers, given "the higher level of pay for medics that specialist Trusts have to fund to top up basic tariff funding".[250]

169.  There was strong independent-sector support for the principle of tariff funding, on the basis that it would allow such providers to make a full contribution to training and be appropriately remunerated. We heard from independent-sector healthcare providers that they were particularly keen to be more involved in postgraduate medical training but found this difficult as they were largely excluded from the current system (financially and otherwise).[251]

170.  The Priory Group, "the largest independent sector provider of mental health, specialist care and specialist education services by number of beds" (which provides a significant number of NHS-funded services), welcomed the commitment to "transparent funding flows for education and training". It told us that, under the current system, "funding arrangements are not consistently applied between regions in England, and funding is often not made available to independent sector providers".[252] We were subsequently also told by Mr Worskett, of the NHS Partners Network, that his organisation liked:

the very sound principle that anybody who is appropriate to do training should be allowed and used to do it, that the money should follow the trainee […] I am sure the people who belong to the Partners Network would want to participate very fully in that and bear their full burden of the training responsibility.[253]

171.  The DH, for its part, was unable in autumn 2011 to give us any more information about its plans for tariff-funding, beyond explaining the principle[254] and assuring us it would "move with care" to avoid destabilisation.[255]

172.  Dame Julie Moore, of the NHS Future Forum, told us as follows about the Forum's proposal for a quality premium to reward excellence in training:

The quality premium you get now for clinical care [under Commissioning for Quality and Innovation (CQUIN)] is a bit of the budget that is held back. If you achieve it, you are given that extra and it is a low percentage, 1% rising to 2%. It could be done similarly to recognise high quality education. Of course very low quality education would be recognised by it being removed.

Her Forum colleague Dr Nightingale explained that a quality "metric" would have to be developed.[256] Professor Tooke, also of the Forum, said this would start with "process measures and stakeholder feedback" but ultimately should be based on measurements of improvement in the quality of patient care.[257] When we asked Professor Tooke whether the quality premium would apply to medical schools, he appeared to indicate to the contrary.[258]

173.  We later heard approval of the quality premium in principle from several quarters, including the independent sector, NHS Employers[259] and two trade unions (the BMA and the RCN). Dr Dolphin, representing the BMA, thought that "We should learn from the tariff for service and make sure that we do not end up with a tariff that simply rewards activity." Although measuring quality in health training was difficult, he thought it could be done.[260]

174.  In From Design to Delivery (January 2012) the DH reiterated its commitment to tariff-based funding for all clinical placements (medical and non-medical) and for postgraduate medical programmes. It noted that this had been supported in consultation responses and by the Future Forum. The Department confirmed that HEE would in future negotiate benchmark prices for non-medical education with higher-education providers.[261]

175.  The DH had been working with stakeholders to develop tariffs for clinical placements and consider how best to implement them without causing unnecessary destabilisation. They would be implemented "in the hospital sector from April 2013, phased over a number of years"; and the Department would work with SHAs and providers on transition plans during 2012-13.[262]

176.  At the same time, the DH was working with stakeholders on developing tariffs for postgraduate medical training (including GP training). This would continue and would include consideration of "an appropriate pace of transition, taking into account the financial impact of the other tariffs".[263]

177.  Lastly, in order to have a robust funding mechanism, "and to reduce the amount of cross subsidisation", the Department planned "to set the education and training tariffs alongside the service tariffs in future." This would take time to develop and embed. The Department would:

work with stakeholders to revise the reference costing methodology to identify the costs of delivering education and training alongside service costing. Until the tariffs can be based on the revised costings, we will seek to minimise the impact of the changes to education and training income to allow providers to plan accordingly.[264]

178.  When Mr Rentoul, of the DH, appeared before us in March 2012 he told us that, in respect of the tariff for clinical placements, there would be "a complex transition" which was "going to take some time" and the DH "working with the strategic health authorities over the next few months to develop transition plans".[265] Regarding the Future Forum's proposed quality premium, Mr Rentoul told us that "We are supportive of that",[266] but it was still "work in progress".[267] He indicated that this was linked to the proposed Outcomes Framework, which would provide "a better set of metrics and indicators that support being able to benchmark performance" and that the premium would operate along the lines of CQUIN.[268]

Conclusions and recommendations

179.  The current arrangements under which providers are paid by the NHS for education and training are anachronistic and anomalous. Payment is only partially based on student or trainees numbers; it is not linked to quality; it is unjustifiably inconsistent between different professional groups, parts of the country and types of provider; and there is an almost total lack of transparency about how it is spent.

180.  Accordingly, we welcome the Government's intention to move payment onto a tariff basis, including a quality premium, as recommended by the NHS Future Forum. However, we note that there is so far slender evidence of progress in converting this desirable policy into a system that will work in practice. Bearing in mind that implementation of the new system is supposed to begin in April 2013, we believe this work needs to attract a greater sense of urgency.

181.  While taking this work forward the Government needs to recognise that there are significant difficulties involved in constructing a workable tariff. It is important that the transition to any new system avoids unnecessary turbulence, and—in particular—threats to the quality of clinical services.

The proposed levy

182.  In Equity and Excellence (July 2010) the Government stated that:

All providers of healthcare services will pay to meet the costs of education and training. Transparent funding flows for education and training will support the level playing field between providers.[269]

In Developing the Healthcare Workforce (December 2010) it was reiterated that there should be "a level playing field in the investment and deployment of education and training funding", enforced by Monitor.[270]

183.  The Government further stated as follows:

Relying solely on market levers to secure sufficient planning and investment in essential healthcare skills is an unacceptable risk for healthcare provision in this country. It would also be unfair if only some healthcare providers bore the costs of providing skills to the local labour market. Over time we intend to move to a levy on healthcare providers to provide the investment needed to train the next generation of healthcare professionals. This will provide a level playing field for healthcare providers and ensure that everyone invests in the totality of education and training required to train future healthcare professionals.[271]

184.  The basis for the proposed levy was further elaborated as being to ensure "that those who are chosen to train the future workforce are rewarded in doing so, and those that undertake less training than they receive the benefit from, contribute to the training provided by others."[272] This would help render transparent "the contribution and benefits for individual providers".[273] It would also "more closely align funding and incentives with the need to secure supply of skills without chronic shortages or oversupply." It was acknowledged that such a significant change would take time to implement, in order to develop appropriate arrangements and avoid unnecessary disruption. Staged implementation was expected, with a notional levy preceding an actual one.[274] A number of consultation questions were asked, including whether the levy should be paid by providers of non-NHS services who "deliver their services using staff trained by the public purse".[275] It was also asked whether public health education and training should be funded by an equivalent levy on public health providers or through central funding.[276]

185.  In From Design to Delivery (January 2012) the DH noted that there were concerns about the practical implementation of the levy, with fears of "potential side effects".[277] The Department promised to "undertake further work and consult widely on how such a levy could be designed, and the possible impact it would have, before we produce firm proposals for formal consultation and possible legislation."[278]

186.  It has often been argued that, as Dr Dolphin of the BMA noted in evidence to us, the independent sector has not been prepared to match the training commitment of the NHS, treating training as "an externality that they can rely on others [i.e. NHS organisations] providing for them".[279] It is clearly right, particularly in view of the expanding role of the independent sector in care provision in recent years, that the independent sector (whether providing NHS-funded care or not) should contribute to the proposed new levy.

187.  The Priory Group accepted the principle of a levy—but was apprehensive about ensuring that it would be remunerated properly for the training it undertook itself. It told us that "Before [a levy] is implemented it is vital that clarity and equity of funding flows [i.e. the education and training tariff system] is established first in order that the levy can deliver maximum benefits."[280] The same view was expressed to us by the Foundation Trust Network.[281]

188.  The NHS Partners Network, however, was straightforwardly hostile to the whole idea of a levy. It argued that imposing a levy on the independent sector could end up being unfair to private providers, "distorting competition" and actually jeopardising existing training provision in the sector, which is often provided, free of charge, to the benefit of the NHS.[282]

189.  The organisation's Director, Mr Worskett, elaborated on this in oral evidence. He told us that, while the existing system contained "a lot of distortions", it was "not working that badly".[283] The danger of introducing a levy was that it could introduce "a different set of distortions".[284] There had long existed a "pluralist system", in which "health professionals of all categories" moved back and forth between NHS and other providers, each undertaking different proportions of work in each sector.[285] For a levy to be fair, the costs and benefits of training to the various players in this system would need to be apportioned precisely by "unravel[ing] this complex plural structure".[286] However, "Trying to unscramble all of that is a huge challenge."[287] Mr Worskett suggested that "we will get into a terrible morass of interlinked issues"—such as the additional costs incurred by private providers due to their inability to use medical trainees in carrying out surgery (in contrast to NHS hospitals).[288]

190.  He told us that the independent sector was already engaged in (largely unrecognised) training of various kinds at its own expense, from which the NHS benefited.[289] Instead of paying a levy, he preferred to see the independent sector make its contribution to training "through doing more of the training ourselves and putting the training in"[290]—although he also indicated that he expected the independent sector in future to be paid for this under the proposed tariff.[291]

191.  Ms Taber, the Director of Independent Healthcare Advisory Services, was also clearly hostile to the idea of a levy. When we asked her whether she wished to see a levy, she told us "No, not particularly. I do not."[292] She thought that it was necessary to dispel the "myth" that the independent sector undertook no training. She agreed with Mr Worskett that much training was currently undertaken in the private sector, free of charge, to the benefit of the NHS but that this was largely unacknowledged.[293]

192.  Like Mr Worskett, she thought that, rather than paying a levy, the independent sector should "work with the LETBs to make sure there are training opportunities—so that we pay our way that way—that will be much better."[294] She added: "I see us being almost mandated or encouraged to provide training opportunities so that we contribute financially that way, in that we provide training in the areas the independent sector works in."[295]

193.  When we heard evidence from healthcare trade unions on this issue they expressed support for a levy paid by all providers, including the independent sector. Dr Carter, of the RCN, pointed out that there were complications around, for instance, the ability to pay of a small residential home—but this could be addressed through taking a proportionate approach.[296]

194.  When the Minister and officials from the DH gave evidence to us in March 2012 they were only able to tell us that the Department was still considering whether to proceed with a levy and, if so, what form it would take. In this regard there was much work still to be done with stakeholders.[297] The Minister told us that there would be some sort of contractual requirement on the independent sector to make a contribution to training—but it had yet to be decided whether this would take the form of paying a levy.[298]

195.  Dr Hamilton, the Director of Medical Education, drew attention to an issue that had been raised with the DH in consultation responses:

an unintended consequence might be that [a levy] would be detrimental to the voluntary or third sector, such as Macmillan nurses, who also provide services. If the levy were to apply to them, that would seem to be unfortunate. That is one of the reasons why it has gone back to be thought about in more detail.[299]

Conclusions and recommendations

196.  We support the Government's intention to introduce a levy on all healthcare providers (whether or not they supply services to the NHS) to provide a more transparent and accountable system of funding for education and training in the health and care sector.

197.  We heard from some independent-sector representatives that they fear a levy would put them at an unfair disadvantage. However, we are unconvinced by these arguments. If there is to be a comprehensive tariff system for funding education and training, as the Government intends, it should be possible for independent-sector providers to be remunerated for training that they undertake on a fair and transparent basis, alongside NHS organisations.

198.  We urge the Government to ensure that the levy system covers social care services, as well as healthcare, to ensure that the education and training system reflects the policy intention to deliver more integrated health and social care services.

199.  We recognise that there are particular concerns about the potential effect of a levy system on smaller voluntary-sector organisations. However, we believe that it is possible to construct workable exemption arrangements to cover these cases and this issue cannot be used to justify the current opaque and unaccountable system.

200.  Although, however, we support the Government's policy objective in this area we note—once again—that there is slender evidence of progress in converting this desirable policy into a system that will work in practice. We believe this work needs to attract a greater sense of urgency.


201.  Although the Government has made clear its intention to fund education and training activity through a system of tariffs and levies, and we support this intention, there remains an urgent need to maintain the current commitment to education and training during the transition.

202.   Although it had been reported that the Multi Professional Education and Training levy (MPET) budget would be cut by up to 15 per cent over three years, beginning in 2011-12,[300] Mr Rentoul, of the Department, informed us that, while possible cuts had been discussed with SHAs, this had been before the overall NHS funding settlement was clear. MPET funding for 2011-12 was actually broadly remaining the same in cash terms.[301] Tim Gilpin, the Director of Workforce and Education for the NHS North of England SHA cluster, confirmed this and said that a similar financial settlement was expected in 2012-13.[302]

203.  However, another witness drew attention to the likely effect of inflation on net funding levels;[303] and it has also been pointed out that the MPET budget is being required to meet significant new cost pressures including from health visitors and psychological therapies as well increased benchmark prices for courses funded from the Non-Medical Education and Training levy.[304] In addition to these cost pressures, there is concern that "raiding" of funds by SHAs might take place in the transitional year. Dame Julie Moore, of the NHS Future Forum, told us in January 2012 that the Forum had recommended HEE be given control of "the full sum that was available this year".[305]

204.  Sir Alan Langlands, of the HEFCE, told us that "We know, from our relationships with SHAs for nursing, midwifery and allied health professions, that over the next three years we are going to see a cut of 14%."[306] million+ told us that "Universities in England have confirmed that the number of commissions is likely to decrease by around 10-15%."[307]

205.  The Nursing and Midwifery PAB told us it was concerned that SHAs were reducing numbers of student nurse commissions, regardless of workforce demand.[308] Manchester University and AHSC referred to 10 per cent cuts in nursing commissions (in 2011-12),[309] while UNISON gave us a figure of 20 per cent.[310] According to million+, some universities were reportedly facing cuts of 50 per cent in midwifery courses.[311]

206.  Mr Rentoul, of the DH, told us that he did not recognise these statistics and that midwifery commissions were actually "still at near record levels". He did, however, acknowledge that there had been some reduction in the number of nursing commissions, reflecting the end of a period of significant growth in NHS funding.[312] When we subsequently questioned the Minister on midwife numbers he told us this was certainly an area where more staff were needed, but he maintained that there were currently record numbers in training; and there had been significant growth in the workforce in recent years.[313]

207.  The AHP-PAB drew attention to the fact that:

Significant reductions in education commissioning for pre-registration AHP student numbers are taking place led by the SHAs/SHA clusters. These reductions are set in the context of increasing demand on MPET and are being implemented without taking account of the advice of the AHP-PAB.[314]

This was reinforced by evidence from the Allied Health Professions Federation, according to which commissions had been cut by up to 30 per cent in recent years.[315] Manchester University and AHSC told us of a 6.4 per cent cut in AHP commissions in 2011-12.[316]


208.  The current system is supposed to allocate specific funds to education and training through a complex series of block grants. It is widely believed that these funds voted are regularly "raided" for other purposes. Mr Gilpin told us that this had not occurred in his region. A small proportion of funding had been held in reserve, but this had still been spent on education and training (either on capital projects or to cover contingencies).[317]

209.  Mr Royles, of NHS Employers, acknowledged in a later evidence session that there were allegations of raiding, but was sceptical as to whether it did actually occur: "What some people mean is that money that they think was ring-fenced to one particular profession is not spent in that profession but is spent somewhere else." There was also a misapprehension that arose from the disjunction between the financial year (which ran from April to April) and the academic year (which ran from September to September).[318] Mr Royles did, though, endorse the principle of ring-fencing education and training funds at the national level.[319]

210.  When we asked Mr Rentoul of the DH, in November 2011, whether raiding of education and training budgets was now going on, he told us "Not to a great extent". He seemed to indicate that the case for giving HEE control of funding was predicated on considerations other than the need to prevent raiding of education and training budgets.[320] When Mr Rentoul again appeared before us in March 2012, alongside the Minister, both agreed that significant raiding of education and training budgets had occurred in the past—but insisted that "in recent years there has been less of it."[321]

211.  Other witnesses, however, insisted both that substantial raiding had occurred in the past and that it was continuing. Professor Sowden, of COPMeD, told us that raiding of budgets by SHAs:

has reduced the investment in the education and training infrastructure for all professional groups. In some areas of the country, that has been much more of a problem than others. It has continued in the last couple of years, in some areas, to the detriment of the system. Those systems are likely to have to pay a price for it in due course.[322]

We also heard from Professor Les Ebdon, the Chair of million+, that:

One practical proposal to safeguard education and training is to ring fence the education and training budget. It has been, in recent years, a soft target for savings and we have seen damage, particularly at the healthcare assistant, nursing and midwifery end of the spectrum.[323]

212.  Dr Carter, of the RCN, specifically challenged the account given by Mr Royles:

despite what people say, the sad fact is that when the health economy is in trouble it is the education and training budgets that are one of the first to be raided. We know, because they tell us, that our members cannot get study leave and the whole continuing professional development is compromised.

He thought it was vital that in the new system LETBs were "set up as legal entities […] so that the money is ring-fenced, they produce budgets and we know that the money ends up where it is intended—that is, to develop and educate the workforce".[324]

213.  Dame Julie Moore, of the NHS Future Forum, told us that the Forum wanted the new system:

to be very transparent so that people knew where the money was going […] Once HEE gets the money, it will go down because it has nothing else to spend it on.[325]

214.  When officials from the Department gave evidence in March 2012, Dr Hamilton, the Director of Medical Education, assured us that HEE, by holding LETBs to account for their expenditure of education and training funds, would be able to make sure those funds were being used for their intended purpose. Regarding arrangements for the transition year of 2012-13, Mr Rentoul told us that:

we have a service level agreement with each of the SHAs for their MPET money with some key performance indicators and what they have to deliver for it. We monitor and track progress. For the 2012-13 financial year, we will continue to do that to protect the money.[326]

Conclusions and recommendations

215.  We heard from the Department that its policy is currently to keep NHS funding for education and training broadly the same in cash terms from year to year. Against a background of inflation and major cost pressures, this is an extremely challenging financial settlement

216.  We have heard evidence that education commissions are being significantly cut. Given the wider financial situation in the NHS, there is also the risk that SHAs will raid education and training budgets in 2012-13, as they have done before.

217.  "Raiding" of education and training funds for other purposes has a long history. While we welcome the Government's willingness to apply a "ring-fence" to the Multi Professional Education and Training levy, we are sceptical about its effectiveness. We believe the Government's plans for more fundamental reform discussed earlier in this chapter represent a more realistic way of safeguarding education and training activity within the health and care system. In the meantime the Government must act to safeguard funding for education and training during 2012-13.

240   Department of Health, Developing the Healthcare Workforce - A consultation on proposals, December 2010, para 8.11 Back

241   Ibid., para 8.12 Back

242   Ibid., para 8.13 Back

243   Ibid., para 8.14 Back

244   Ibid., para 8.15 Back

245   Q 146 Back

246   Q 145; cf. Qq 117, 146 Back

247   Ev w196 Back

248   Loc. cit.; Ev w161 Back

249   Ev w98; cf. Ev w33 Back

250   Ev w87 Back

251   Ev w18, w205 Back

252   Ev w18 Back

253   Q 350 Back

254   Qq 73-4 Back

255   Q 75 Back

256   Q 258 Back

257   Loc. cit. Back

258   Q 264 Back

259   Q 358 Back

260   Q 392 Back

261   Department of Health, From Design to Delivery, January 2012, paras 131-4 Back

262   Ibid., para 136 Back

263   Ibid., para 137 Back

264   Ibid., para 138 Back

265   Q 516 Back

266   Q 518 Back

267   Q 519 Back

268   Loc. cit. Back

269   Department of Health, Cm 7881, July 2010, para 4.33 Back

270   Department of Health, Developing the Healthcare Workforce - A consultation on proposals, December 2010, para 6.21 Back

271   Ibid., para 8.2; cf. para 1.4 Back

272   Ibid., para 8.16 Back

273   Ibid., para 8.17 Back

274   Ibid., para 8.18 Back

275   Ibid., Question 36 (p 58) Back

276   Ibid., para 7.10; Question 27 (p 53) Back

277   Department of Health, From Design to Delivery, January 2012, para 140 Back

278   Ibid., para 141 Back

279   Q 377 Back

280   Ev w18 Back

281   Ev w74 Back

282   Ev 150; Charlotte Santry, "Private sector warns of training levy danger", Health Service Journal, 10 November 2011, pp 10-11 Back

283   Q 350; cf. Q 356 Back

284   Q 350 Back

285   Q 351 Back

286   Q 355 Back

287   Q 351 Back

288   Q 356 Back

289   Qq 305, 350, 355, 362-3, 366 Back

290   Q 353 Back

291   Q 350 Back

292   Loc. cit. Back

293   Qq 335, 340-1, 354-5, 359-60, 363-6; cf. Ev 166 Back

294   Q 347 Back

295   Q 349 Back

296   Qq 390-1 Back

297   Qq 523-5 Back

298   Q 526 Back

299   Q 527 Back

300   Ev 141; cf. South Central Strategic Health Authority, "Workforce demand and supply modelling to 2010-15", August 2010, p 5 Back

301   Q 69 Back

302   Q 110 Back

303   Loc. cit. [Mr Sharp] Back

304   Ev w195; Qq 71, 87, 110; Seamus Ward, "Training on target?", Healthcare Finance, March 2011, p 19 Back

305   Q 252 Back

306   Q 145 Back

307   Ev 141 Back

308   Ev 106 Back

309   Ev w199 Back

310   Q 387 Back

311   Ev 141 Back

312   Q 72 Back

313   Q 495 Back

314   Ev 109 Back

315   Ev w240 Back

316   Ev w199 Back

317   Qq 100-3 Back

318   Q 357 Back

319   Q 345; cf. Ev 161 Back

320   Q 18 Back

321   Q 515 [Mr Rentoul] Back

322   Q 164 Back

323   Q 176 Back

324   Q 387 Back

325   Q 252 Back

326   Q 513 Back

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Prepared 23 May 2012