Draft legislation to merge Scotland's further and higher education funding councils has come under attack from vice-chancellors, trade unions and students.
Responses to the Scottish Executive's consultation on the merger plans reveal concerns that the legislation could open the door to large-scale cost-cutting and could give the Government unjustified and unnecessary powers.
The consultation has raised expectations that the proposed legislation will be revised radically before going to the Scottish Parliament in the autumn.
In its submission, Universities Scotland has warned that it will withdraw its support for the merger if there is any hint that it will lead to cost-cutting. It worries that the legislation could be used to cut resources for university teaching by basing funds on the qualification levels established by the Scottish Credit and Qualifications Framework.
This puts a higher national certificate course at the same level as the first year of a university degree.
"Funding must reflect the fact that different programmes at the same SCQF level offer different learning experiences," the Universities Scotland response says.
The Association of University Teachers Scotland fears funding by level would lead to universities abandoning higher national courses and colleges focusing on higher education at the expense of further education.
In an unprecedented joint submission, made in addition to their individual responses, Universities Scotland and the Association of Scottish Colleges argue that the Bill is misconceived and could lead to political interference and increase the funding body's role at the expense of governing bodies.
A Scottish Executive spokesperson said: "We are encouraged to receive a joint submission from the Association of Scottish Colleges and Universities Scotland. Collaboration between the sectors is exactly what we are trying to encourage with the merger of the funding councils."
Throughout the consultation, the concerns of the ASC and Universities Scotland had been discussed in detail, she said. "These will be taken on board, alongside the responses from all other stakeholders, in refining the final Bill."
The National Union of Students Scotland is more supportive of the plans, but the Coalition of Higher Education Students in Scotland opposes the provision that allows ministers to act if they think it "necessary or expedient". This seems to give ministers an unfettered power to be exercised at will, Chess said. Even if that is not the aim, future ministers could misuse the power, it added.