The Office for Students (OfS) ‘Consultation on a new approach to regulating equality of opportunity in English higher education’ closed at noon today. It marks an ‘upping the ante’ on universities that are already under severe pressure. By putting the onus on universities to enable wider participation, the OfS risks diverting attention away from the wider societal divisions that are outside the control of universities. The proposals are also overly complex and burdensome. They will be a greater draw on resources than is possible to offer and will seep into every corner of the universities trying to comply. Universities cannot alone cure the ills of the inequalities in education across the board and the OfS should put their plans into the context of wider strategies and deployment of resources. TEFS has responded by asking for greater clarity and radical simplification that acknowledges the limited role universities are able to play in the wider problem.
The easy way out to reach expected widening participation targets might be for highly selective universities to ‘lower’ or adjust their entrance requirements for some students. Different criteria for selection might be deployed other than the attainment reached in one-off examinations. It’s surely not as simple as that and, if done more diligently, the effect might be to attract those with greater ability and potential to universities.
An easy way out.
For any university highly selective in its entry requirements, they face a major challenge ahead. There is a real dilemma between balancing those requirements against widening participation. Rather than attempting to fix the whole state school provision, and social inequalities in general, the simplest way out would be to lower the entrance requirements for some state school students with fewer advantages.
Yet the OfS expects universities to “focus on both increasing activity to raise attainment in schools and also (sic) addressing the most significant risks to equality of opportunity for individual providers. This is intended to ensure that students are equipped to access higher education”. This is impossible in the shorter term and only likely to succeed with wider interventions at huge cost. The ‘easy way out’ of lower entrance requirements becomes an attractive route.
Unintended consequences.
In its drive for widening participation of less advantaged groups of students, the OfS is piling the onus onto the universities to take those students and support them throughout. All of this in the context of a diminishing resource. The blame for failure is being shifted steadily away from the government. An unintended consequence could be a radical change in how students are examined and assessed. There may be a seismic shift away from one-off exam attainment, dependent upon the type of school and teaching resources, to wider assessments of ability and potential. This may become the main feature of the broader baccalaureate curriculum being proposed by the new guard at the Department for Education (see TEFS 4th November 2022 ‘Changing the guard at the Department for Education and the labours of Halfon’)
Reactions to the drive for widening participation.
It was therefore no coincidence that last week the Telegraph started a fierce campaign against lower grades being allowed for some students to achieve a wider socioeconomic intake at the elite universities. Parents paying for a private education for their offspring expect to get a return on their investment and never mind the unequal advantage.
Pandering to this expectation, on Friday the Telegraph reported that there was a ‘Fear of Oxbridge bias against fee-paying schools’. Only the day before they had complained, ‘Cambridge accused of ‘social engineering’ as state school pupils now more likely to get a place’. In a follow up on Sunday they wanted ‘Oxford University urged to publish entrance exam results amid bias row ‘. The idea and hope being that independent school students must be inherently better at such examinations.
This all follows on from a year ago when they reported that, ‘Universities set own entrance exams amid A-level chaos’. It seems universities are turning to entrance exams because they can no longer rely on A-levels to find the brightest students amid a “tsunami” of top grades. Maybe they never could have been sure of their worth.
Attainment and ability.
More recognition that ability might be spread evenly across the population than the school exam results might suggest will lead to a realisation that the system is broken.
Of course, the Oxbridge universities have regularly used entrance examinations and interviews in one form or another and other universities are also moving in this direction (see TEFS 22nd October 2022 ‘Attainment gaps and questioning the purpose of examinations’). If too many students achieve A or A* grades at A-level, then to fill the limited places they must add on other means of assessment. In doing so, they will already understand ‘attainment’ of grades is often a measure of a school’s teaching and facilities and not necessarily a good measure of a student’s ‘ability’ or potential (see TEFS 11th December 2020 ‘Are the teachers or the students being assessed?’). Selection based on ability or potential becomes a better option to widen the pool. But the danger lies in some able students not having gained critical knowledge that might be assumed by university staff on many courses. It’s a fine balance and requires the resetting of how courses might be delivered.
Setting attainment in context attracts more able students.
The consequence of adopting a ‘contextual admissions’ approach, by setting a student’s attainment against the school environment they might have endured in the state system, is that it will attract more complaints of lowering standards. But less advantaged students are surely expected to do less well than a student of similar ability housed in smaller classes in a well-resourced independent school. This recognition is likely to become the usual approach for many of the so called ‘high tariff’ elite universities. But this could backfire on those complaining of bias. Rather than lowering standards, the inclusion of more assessments of ability and potential is more likely to improve standards. A perverse effect in the eyes of those with greater advantages, but a good thing for society.
The OfS style objectives.
Enter the OfS into the fray. Their approach is based upon regulation and offers fewer options on the means and resources to reach the objectives. Listed are he overarching demands with an ominous rider about planning for the potential of a course closure to focus the mind.
“All students, from all backgrounds, and with the ability and desire to undertake higher education: are supported to access, succeed in, and progress from, higher education, receive a high quality academic experience, and their interests are protected while they study or in the event of provider, campus or course closure, are able to progress into employment or further study, and their qualifications hold their value over time, receive value for money”.
Principles and risk.
Since 2017 the OfS has taken a ‘risk-based regulation approach’ with a view to lowering the administrative burden on universities. By 2020, this had morphed into a ‘Principle based regulation’ approach bolted onto the risk angle. This was to continue to reduce the administrative burden. However, the current moves are putting even greater strain on universities and their resources. Not only must they widen participation, but they must also be seen to do so through incessant evidence gathering.
In simple terms, the OfS sets out the “minimum levels, or ‘baselines’, that a higher education provider must achieve”. Then “monitoring compliance, targeting our work where it is most needed – on those providers most at risk of breaching our conditions – and focusing on reducing burden on those that do not pose a specific regulatory risk”.
Setting targets.
The key lever to be pulled is to make universities themselves generate suitable Access and participation plans or APPs. Dare I say ‘dig their own graves’. I am reminded of the scene in ‘The Good, the Bad, and the Ugly’ from1966 where Clint Eastwood hovers over the man he is compelling to dig a grave. He offers this observation “You see, in this world, there’s two kinds of people, my friend: Those with loaded guns and those who dig. You dig.”
Similarly, our universities must produce their own plans and “objectives should be translated into numerical targets with measurable outcomes-based milestones set over the duration of a plan”. Investment must be clearly set out and “Targets should be captured in a targets and investment plan”. In terms of curbing administration for universities, this means even more digging with “we propose that universities and colleges themselves should lead on shaping the appropriate interventions to mitigate those risks, led by the evidence”. Then there’s more with “we expect providers to contribute to a significant, ongoing expansion of that evidence base through meaningful commitments to undertake and publish high quality evaluations of the work they commit to in their access and participation plans”.
Raising attainment in schools.
The OfS expects universities to raise attainment of students in schools. This is thought to be best achieved through collaborations and partnerships with schools. However, it’s a piecemeal strategy that appears flawed. This is because it expects universities to operate alone in choosing schools when offering help. They may be reluctant to do this alone. The only way this approach will work is it there is a national strategy and initiative that transcends individual universities and is more centrally coordinated. Universities would feed into this by offering some of their resources to inform and mentor students. Better support in schools for children with few advantages at home would be a better start and universities may have little to offer directly.
The fictional examples in the consultation reveal a worrying trend.
Annex F contains some “Fictional illustrative examples of how a provider can meet the OfS’s expectations”. They provide a very revealing view of the OfS’s idea of widening participation.
At one end we have the University of Wrottesley, a post 92 university in a large city with, “No significant risks to equality of opportunity identified”. It is expected to set an example for others at the leading edge of this work and should “consider how they might innovate further, evaluate their work and share the findings”.
This is counterbalanced by the University of Edgestow, a “multi-faculty provider with an international reputation for teaching and research”. Historically, this is a well-established and highly selective provider drawing a much larger proportion of its undergraduates from the independent sector than is consistent with the number of such students in the wider population. The OfS sees this as a “risk to equality of opportunity in relation to insufficient diversity in access, particularly in relation to socioeconomic and ethnic groups”.
The solution for this ‘provider’ is simple as it, “needs to consider carefully how it can deploy its teaching and research to ensure that more applicants, from a more diverse range of socioeconomic and ethnic backgrounds, are ready and able to be admitted. This suggests a significant contribution to both pre-16 attainment raising and ensuring that information about and support through its admission processes are available so that such students feel confident in engaging”.
TEFS response to the Consultation.
There are twenty-two questions posed by the OfS. Eighteen are related to specific proposals and another four related to the whole consultation. Many are the concern of the universities and how they view what the regulation expects of them. This especially relates to the form and duration of their APPs. TEFS is not in a position to speak for them. However, there are some proposals that have wider consequences and TEFS has asked for more consideration of this. Setting objectives “translated into numerical targets with measurable outcomes-based milestones” will mean universities try to achieve this using the route of least resistance.
Raising attainment in schools and collaboration with schools and colleges is particularly problematical. Done in a piecemeal way and it will cause considerable inequalities with some schools gaining where other miss out. A better coordinated national scheme that universities can buy into would be a better approach.
With declining resource and unit costs the scope for greater investment is limited. The expectation that universities will release more funds for hardship and bursaries might turn out to be unrealistic
The author, Mike Larkin, retired from Queen’s University Belfast after 37 years teaching Microbiology, Biochemistry and Genetics.