In responding, GuildHE highlighted that both models have drawbacks; the ‘bottom-up’ approach increases the burden on institutions, while the ‘by exception’ methodology’ does not provide robust conclusions to meet the policy objective. GuildHE also called for a greater role for student voice, through a student submission to TEF panels, and reiterated concerns about the use of LEO data in the methodology.
GuildHE’s full response can be read here.
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