GuildHE have responded to the OfS consultation on the future approach to regulating equality of opportunity in English higher education. Overall we are grateful to the OfS for recognising – in the case of APPs – the substantial burden the current process has on smaller HEIs and welcome a new approach which enables institutions to focus their equality work on those issues which require specific research and evaluation.
There is a great deal of activity within the sector concerning the transition in, through, and out of HE for those students who require additional support both in terms of protected characteristics and WP characteristics. We, therefore, hope that the new plans will enable providers to hone in on specific activities (proportionate to their size, context, and mission) which target their students with the greatest need and to have the resources to undertake strong research methodologies and evaluation.
However, we must recognise that this shift to APPs focusing on very specific, targeted and measurable activity does not take away from the fact that the sector is seeing unprecedented demands on student support and substantially increased costs to delivery.
So whilst we agree with much of the direction of travel we are concerned that the document is still very focused on access and not on participation. This is particularly seen in the expectation in relation to raising school attainment.
Current concerns include the cost of living crisis, social anxiety and mental health crisis, bridging lost learning for existing students, risks to adult participation due to family/employment issues, systemic societal disadvantage due to protected characteristics, potential post-graduation employment issues through the present-day turbulent economic times, and the substantial research base we have around the way in which students with different characteristics experience HE and the very many barriers to the full student experience.
These factors lead us to believe that the OfS haven’t provided enough thought and direction over the way in which they are expecting APPs to support current students and their success through and beyond HE.
We believe there is a powerful case for investment through the APP process in continuation, achievement and progression into employment and would like to see more information, guidance and practice sharing at the OfS concerning the full student lifecycle, whilst also considering the huge financial pressures HEIs face due to the fee freeze and current economic environment.
Specifically on raising attainment, whilst we generally agree that some HEIs will have specific expertise and resources to support individuals and schools to improve, we think at a national level this will best be delivered through a change to the UniConnect programme which was set up to work directly with schools and improve school-college-university relationships. We think this would work more effectively and efficiently, rather than requiring all institutions to have a specific individual target in this area.
We also highlighted our frustration that such an important issue is only given five weeks of consultation at a time when there are a great many pressures on HEIs for their time and resources. Many smaller HEIs have struggled with the capacity to provide meaningful feedback on these proposals and we wish the OfS to think more specifically about how it can ensure that small HEIs have an equal opportunity to contribute to policy development and have their say on proposals. In our experience, policy is rarely, if at all, developed with small providers in mind, and there are often hidden or unintended consequences within policy proposals that disadvantage smaller institutions. This is one of the reasons why we have launched a new series of briefings looking at the regulatory burden for small and specialist institutions more broadly.