The cracks dividing the government’s vision of Higher Education and that of the HE institutions in England are becoming wider. It is hard to ignore the dangers of the rift as the main regulator, the Office for Students, flexes its muscles.
In the last two weeks, we have seen the closing of three major consultations on policy that will impact the sector in a profound manner. They represent a shifting of blame for any short fall in equality of access directly onto the sector and absolve the government of any policy failing. They also add to increasing pressure on universities at a time when inflation is fast eating into their resources.
The three consultations opened in late January and revolved around ‘Student outcomes’ (pdf), ‘The Teaching Excellence Framework (TEF)’ (pdf) and ‘Student outcome and experiences data indicators’ (pdf). These were large documents that posed many questions and concerns. However, there was also very little time to react before they were closed to responses. It seemed that minds had already been made up. TEFS reviewed them in January with ‘OfS consultations: Higher Education regulation by decimation’ and noted the likely impact on widening access as it tries to balance this with the so called ‘standards’ requirement. Basically, this crudely looks at outcomes and graduate jobs as proxy measures for ‘standards’. A notion that must be astounding to people working in universities.
University responses blow cold on the ideas.
It comes as little surprise that the university sector is very alarmed by the proposals. They are coming under extreme pressure on their resources as the government demands increase fast. Inflation and increased taxes will eat into every corner of their operations.
Universities UK, who represent all universities across the UK, responded under the headline ‘Excessive admin will take focus away from teaching, universities warn regulator’. They pulled no punches with, “There is a danger that narrow definitions of quality and good outcomes will discourage innovation and penalise universities working with students from disadvantaged backgrounds or on non-traditional courses.”
They are right, the plans will add further pressure on universities to conform to a ‘faux’ standard and deflect them from their mission. Their detailed responses pile on the criticism of the government’s approach. On access and participation, they challenge the government with “We think the OfS needs to consider the potential unintended consequences of these proposals and mitigating actions in an equality impact statement.” This should be done with urgency. The lack of ‘UK-wide coherence’ in policies is another danger point that must be addressed.
The Million+ group of universities also criticised the proposals in a detailed response. They represent mainly the larger post-92 institutions and may have more to lose in the fallout. Similarly, the representative group of smaller institutions, Guild HE, reached the same general conclusions. Its deputy chief executive, Alex Bols summarises the problem of trust in the OfS by the sector with a plea in WONKHE, “the key issue that the OfS will need to consider is how it goes about rebuilding trust, which in a largely compliant sector is essential for good regulation and efficient use of resources”. He stressed the widening gap in positions being taken by both parties.
Sitting outside of most of these concerns is the main response of the Russell Group of ‘elite’ research intensive universities. They were very brief in their response and were generally supportive at the outset. This is because they do not expect a major impact on their own operations. Their focus is now more on research capacity, and the recently announced Russell Group response to new UKRI strategy, when commenting on the publication of Transforming Tomorrow Together. This is the UK Research and Innovation (UKRI) strategy following from the government’s recent ‘Research, development and innovation (RDI) landscape review’ led by Paul Nurse.
On the data proposals there is considerable confusion about the link to HESA data and this should have been clearer. The link to the roll-out of ‘Data Futures’, after a consultation that ended earlier in February, is confused. However, it seems the OfS will determine how data is analysed and presented to match their policies. This is a dangerous move and a clash with HESA, owned by the universities themselves, seems inevitable. The OfS ‘interpretation’ of HESA data will become ‘interesting’ at best. TEFS expects some data fields will mysteriously fade away sacrificed at the altar of reducing the burden on universities. This would be a trap they can ill afford to fall into.
However, it is also less clear to UUK how these moves fit with the increased burdens on universities arising from a change of direction with “We have concerns with the long-term sustainability of the approach outlined in the consultation given upcoming fundamental changes to collection of data”. The plan is for more data points in the year with more focus on individuals. This has its merits, but TEFS also sees scope for considerable disruption and confusion at a time when universities can ill afford the distraction.
TEF becomes a big stick.
TEFS view of the Teaching Excellence Framework (TEF) is that it represents an irrelevance. But to give it more bite, the OfS plans to add another category of unsatisfactory under the banner of ‘Absence of excellence’ and no rating awarded. This is a category that appears to be above the minimum standards needed and below the gold, silver, and bronze levels. Sure enough, UUK and universities are concerned about this plan alongside two mechanisms of quality running together. They state “The OfS needs to avoid trying to do the same thing with two separate mechanisms, to avoid unnecessary burden and potentially conflicting approaches”. The purpose might be to deploy their requirement for “excellence in relation to the experience and outcomes of their students” to lean on institutions short of closing their operations down. In constructing the proposals they took account of the independent review of the TEF (aka the Pearce review), the findings of the latest subject-level TEF pilot, and the government’s response.
The OfS strategy.
This was opened for a consultation back in November 2021 and closed on the 6th of January 2022. The final ‘Office for Students Strategy 2022 to 2025’ was revealed on 23rd of March 2022 and little had changed. Readers must have been puzzled by the continued lack of references to ‘widening access’ and introduction of the ill-defined term ‘equality of opportunity’. This is spattered about many times in the document without seeming to be focused on what it might mean in practice. Could it simply mean that every student will get an opportunity to take out a large loan to bet on a degree? Those with long odds may be scratched with odds on others shortening in time.
A clue to the hardening approach of the OfS was only too apparent in comments made by John Blake, the director for fair access and participation in an interview with iNews last week. Noting that it was “absolutely the case that some people have left university with a damn sight less than they were promised” he demanded that universities should not “shield” themselves from “legitimate questions” about the quality of their courses by hiding “under the bodies of disadvantaged students”. This is highly offensive to those teaching in Universities and he should know better. He has hammered a deeper wedge into the opening crack in trust between government and universities. This does not look good for the notion that there might be any real support for disadvantaged students.
Standards and quality.
This is truly mysterious for those looking at the OfS offering. The notions of ‘quality and standards’ are raised many times. For example, “OfS is focused on ensuring through our regulation of quality and standards that all students, whatever their background and characteristics, can have confidence that they will receive a high quality higher education and positive outcomes”. Yet, this is outlined without any reference at all to the role of the Quality Assurance Agency (QAA). This is astounding with QAA currently celebrating its 25th Anniversary. During that time, they have been acting independently as a charity to “maintain and enhance quality and standards”. Instead, it is planned that “The OfS will itself assess the provider’s compliance with this initial condition and will not commission the designated quality body to undertake assessment activity”. This applies to assessing initial condition B3 for registration whereby “The provider must deliver successful outcomes for all of its students, which are recognised and valued by employers, and/or enable further study”.
It seems the views of the QAA might quickly clash with those of the OfS. Not to worry though, a new body will be used to paper over any cracks and operate independently from QAA; but still using QAA data. Indeed, the alleged Designated Quality Body (DQB) appears to exist as this is written. QAA announced the birth on 22nd March 2022 stressing its separateness from QAA and “operational independence” and already “provides assessments and advice for the Office for Students on quality and standards in higher education in England”. Unlike the QAA, that covers the whole of the UK, it covers England only and will have new management and a board “independent of the QAA Board”. No doubt the OfS will decide who they can work with. In the meantime, to many observers caught in the crossfire, this smells of a rigged set up propped up by the OfS interpretation of data.
Possible end game.
Back in September of last year in, ‘Privatisation storm looms for universities’, TEFS proposed the possibility of some universities moving to a private status in response to the increasing pressure. Most will have at least assessed the possibility. The pressure is getting worse as income fails to balance with inflation costs and more demands on their resources. Those with income from large numbers of international students might see this as attractive. It is not beyond the realms of possibility that they could set their own fees and service loan schemes outside of the Student Loans Company. Bypassing expensive pensions and collective agreements through trade union recognition might also begin to look more attractive. Barring that radical move, some might seek to reduce their unit costs through mergers or spawning commercial offshoots. While this story today in ‘The Tab’ about ‘leaked documents’ confirming ‘The University of Leeds and Leeds Beckett to merge from September 2022’ is an April Fool joke, it has a terrible ring of truth to it. The ‘official’ quote “Money that we save through sharing lecture theatres and lecturers can instead be invested in building upon our resources as we move out of the pandemic, making studying in Leeds better than ever before” is far too realistic.