As I finalise the GuildHE response to the HEFCE Quality Assessment Consultation I have been surprised by the strength of feeling that the consultation has provoked in the discussions I’ve been involved with, draft responses I’ve seen and the round-table that we organised.

So it is perhaps worth starting by saying that we welcome the fact that HEFCE has opened up this debate, and that their radical proposals have generated real discussion around key questions about how to develop a robust system for quality assessment for the future.

It is always important to reflect on how we can improve the regulatory framework and make it fit for the future and the consultation rightly focuses on a number of key areas where there is more thought needed. However, whilst provoking discussion, there doesn’t – yet – seem to be a consensus developing, and so perhaps we should take the opportunity provided by BIS’s TEF proposals to look afresh at this area and GuildHE looks forward to playing a proactive role in this.

Mature and co-regulated sector

One of the features of UK higher education is that our institutions have well-established and robust quality assurance processes that delivers a world-class education. This excellence, and the central role of institutional autonomy, is recognised by the way in which the quality assurance and assessment framework has been established and developed over many years through a process of co-ownership and co-regulation. These principles should remain at the heart of any new system.

With the vast majority of quality assurance happening within institutions – and the recognition of the efficacy of these processes – it has shown that the sector can be trusted to play a major role in co-regulating this activity. This wider recognition of the strength of the system also underpins the principle of co-ownership of bodies such as the QAA by the sector – represented by GuildHE and UniversitiesUK – and also the central role of peer-review within quality assurance.

We would reiterate the importance of an independent, co-owned national body to provide the external, peer-reviewed assessment of quality that is central to providing wider assurance. This co-ownership of the QAA means that the sector is able to help steer its work and can also play a key role in re-shaping it to be fit for the future, something that would be much harder in a Government-controlled body. It may not be the best possible QAA it could be, but it’s ours and we have the power to change it!

Institutional governance

The proposals surrounding strengthening institutional governance rightly recognise the primacy of institutional autonomy and point to an area that institutions could usefully focus more emphasis. However it is worth highlighting that the dual governance system based on both academic governance (through academic board/senate etc.) and the governance of the institution (provided through Board of Governors, Council etc.) is one of the strengths of the UK HE system and we wouldn’t want to destabilise this delicate balance.

At a principle level we agree that the governing body should reassure itself more that the quality management processes are being carried out but there was a strong feeling that the governing body shouldn’t be trying to actually manage academic standards themselves – which the consultation seemed to imply in various places. It is worth noting that the revised CUC Guidance in this area is still relatively new and will take more time to embed and we should review how this is being implemented.

On a more practical level there are real questions as to whether governing bodies currently have the required skillset to be able to do this effectively and in order to be able to do this whether it might result in a less diverse governing body with more governors with an HE background which could impact on either the size of the governing body or a reduction in those with business and financial backgrounds. There was also a concern that governors might need to bring in external consultants to provide them with suitable independent assurance, which might end up not being any cheaper than the current costs, whilst losing the peer-review dimension.

External examining 

The proposals to enhance external examining provide an opportunity to consider how to further strengthen this key element in the quality infrastructure but whilst there was support for the principle of strengthening external examining, the sector’s rejection of a register four years ago through the Finch Review doesn’t seem to have changed.

Concern about perceived bureaucratic processes such as accreditation and training to join a register might deter existing senior academics and industry professionals and would need to be flexible enough to incorporate different skills and knowledge required from professional and industry experts. There was also concern about whether the register would adequately reflect smaller or more specialist disciplines and so might unintentionally restrict choice of experts.

There was a suggestion that perhaps a less bureaucratic “list” might seem a more appropriate starting point which institutions can easily add to, rather than a “register”, but we would of course need to consider how the list would be maintained and updated. GuildHE look forward to working with Universities UK and others to help develop proposals to further strengthen the external examining system as proposed in the consultation.


Our members also stressed the importance of maintaining a UK-wide framework and linking the process with the TEF, particularly in relation to the Minister’s call for independent, external, cyclical peer review. The HEFCE consultation helpfully highlights areas where there could be more focus and thought, particularly surrounding external examining and the role of the governing body, but that there is still more discussion needed in the exact form that this might take and we look forward to engaging with these discussions.