As the OfS’s consultation on Quality and Standards closes it is important to take note that last week’s raft of policy announcements made clear that the DfE is still likely to want to have a say on a number of related issues including what further reforms may be needed to tackle “low quality” courses. They have also expressed much interest in recent years in issues such as “grade inflation” and value for money and so may also return to these topics.

The DfE did, however, provide some clarity around some other integral issues such as the Teaching Excellence Framework, which will be retained at an institutional level and run every four or five years and perhaps greater consideration of subject level information if not making judgements on the basis of these. DfE also suggested adding an additional grade for institutions requiring improvement, but how this relates to OfS’s quality processes and ongoing monitoring, as opposed to enhancement above the baseline, will be interesting consideration. There was also a steer towards the review of the National Student Survey Review that it should better reflect student academic experiences rather than levels of satisfaction.

This will all give the OfS much to consider as it reflects on the responses to the consultation and draws together its proposals for the second phase of consultation. Ahead of that we wanted to flag three broad principles to shape the next phase of consultation.

1) The English quality assessment system must sit within a UK-wide framework
2) Providers should only be judged on things directly within their control
3) Data is a helpful tool but a poor master particularly in smaller providers

These three principles underpinned GuildHE’s response to the OfS’s Quality and Standards Consultation.

Retain UK-wide framework

An underpinning feature of the quality assessment system should be to ensure a UK-wide framework within which the different national approaches all sit. This is particularly important given the UK’s international reputation for high quality education supports international
student recruitment and partnerships, and other countries look at the UK as a whole rather than the different approaches in the four nations. It is also important that in a single United Kingdom of four nations that we facilitate graduate mobility around the country through a national quality framework.

In the current Regulatory Framework this “UK-ness” is mainly expressed through alignment with the Quality Code, and in particular reference to the Core Practices and Expectations that apply to the whole UK. We therefore believe that the English system should continue to be aligned to Quality Code in order to retain the UK-dimension. If the OfS does decide to press ahead with removing references to the Quality Code then they must replace that with measures to protect a UK-wide quality assessment system.

Judge providers on things within their control

The proposal to not benchmark progression data for graduate into professional and managerial employment will unfairly penalise institutions for issues beyond their control. There are structural inequalities within society that impact on the type and level of jobs that people are appointed to. There are also likely to be regional differences in current skills needs and not considering this factor by removing benchmarks might negatively impact on Government plans to “level-up” regional economies. Not benchmarking this data for progression to professional and managerial employment will unfairly penalise institutions for issues beyond their control. We therefore propose that the OfS must retain benchmarked data on the progression measure.

Reliance on data for institutions with small cohorts

The OfS’s proposals for more reliance on numerical baseline data places an enhanced reliance on the robustness of the data. The majority of providers on the OfS register have either small student numbers, or many courses with small numbers, all of which means that the data is unlikely to be statistically robust to make regulatory decisions, especially when looking at the intersection of different student characteristics. The second phase of the consultation needs to make clear how this will work in the vast majority of providers on the OfS register with small cohorts of students and data that is more likely to fluctuate on a year to year basis. The second phase consultation should also consider the possible risks of aggregation which may hide some very good or very poor outcomes.

Conclusion

We look forward to working with the OfS to develop a quality and standards system that further strengthens our reputation and track-record for delivering excellent education whilst focuses most attention on those small pockets where the quality may not be as good.