Westminster Forum Event keynote: next steps for the Teaching Excellence Framework

If you aren’t aware of who we are, GuildHE is a formal representative body for over 70 diverse HE institutions.

Our members are small and large, rural and urban, practice-based and online, publicly and privately funded. This extensive diversity offers us a unique and valuable perspective on the sector's current challenges and opportunities, and we consider ourselves a key indicator of how policy changes affect a diverse sector.

Therefore, our consultation response is fundamentally guided by the need for a robust, fair, and proportionate regulatory system that fosters - rather than hinders - quality and innovation across all providers, regardless of their size.

Quite rightly, this government has recently committed to ensuring we maintain our world-class status of delivering very high quality experience. We should never rest on our laurels in assuming this will continue without a continued examination of how best to do this and because we have legal autonomy in setting academic standards, we have a sector with a rich history in collaboration across the UKvHE landscape. 

We’ve had the TEF for a while now, and it has evolved and been experimental at times (in the case of subject level) and we now look to another iteration of the process. This time the exercise is trying to streamline the connection of the TEF with other regularity conditions.

The Office for Students has already taken a lot of sector feedback on board, which is positive. We particularly welcome the move towards a single, unified approach to quality regulation, bringing together B3, Access and Participation, and TEF methodologies in the data and more conceptually. We also support the drive for the OfS approach to be recognised as adhering to European standards and guidelines for quality assurance, as this is vital for increasing confidence in our system and enhancing opportunities for international partnerships.

However, we have some significant concerns.

Firstly, there are still huge questions about the link between what the TEF measures and actual academic quality (the day to day student experience). The now huge body of research suggests this is not straightforward. The current activity still leans heavily on evaluating outcomes purely in data terms, rather than assessing the robust quality assurance that underpins the academic portfolio and the student experience. The TEF continues to fall into the trap of counting what they can measure, rather than measuring what counts.

A heavy reliance on metrics often creates performative behaviours designed to improve data, without a broader reflection on what is genuinely good for students. The proposed TEF continues to lean into market ideologies to regulate education, which many, including GuildHE, argue is not appropriate for the HE sector in measuring the totality of academic quality and is not in keeping with the collaborative and cooperative vision set out in the white paper.

This reliance on data is also particularly problematic for providers with smaller cohorts. The statistical significance of data, or lack thereof, is critical. Smaller providers often have less publishable data or lower data confidence ratings, creating an uneven playing field. When you have a course cohort of 25 - the data can be wildly variable from year to year, which is less of the case in institutions where 500 students are on the same programme.

While benchmarks offer some utility, a provider's final TEF rating is inherently relative. Performance is measured against a benchmark, and since that benchmark is based on sector averages, some providers will, by definition, fall above and some below it, regardless of their absolute performance (e.g., 99% or 50%). Consequently, the TEF system incentivises providers to compete against their peer group rather than focusing on the quality of their student experience.

Therefore, a fair assessment of teaching quality across the diversity of HE providers cannot be assessed by metrics alone - and that's before anyone makes suggestions about the validity of the specific NSS questions and datapoints in evaluating quality.

A balance between data and contextual commentary is essential to mitigate this, and we are therefore troubled with the approach being consulted on about minimising the contextual institutional submission. 

We also fundamentally disagree that any salary-based benchmark is an indicator of HE provision quality. Research from the Institute for Fiscal Studies clearly shows that salary is linked unilaterally to school-level academic attainment, social class, and employer perception of prestige, not to actual academic or teaching quality. The quality of the university experience is only a small factor in salary outcomes, as evidenced by significant and stark gender salary differences early in careers, even at the most selective universities.

There is of course an interesting conversation to be had about the onward value of a degree, and some of that could be contextualised with earnings, but our industries are not homogeneous, and we are autonomous people. 

Earnings depend on gender, regions, specific entry points into industries, and how those industries organise themselves. Creative and agricultural graduate salaries for example are often low for the majority of people, not because these skills aren’t complex, valued and vital, but by the culture of these professions and industry profit margins. Yes, we can benchmark this - but it still only weakly corresponds to the subject content and provider you attended.

Furthermore, we must address the issue of specialist and postgraduate-focused institutions. Until PG students are fully integrated into the TEF assessment, these providers are unfairly disadvantaged, receiving ratings that could carry substantial business repercussions based on only a small portion of their student body. Government proposals to link tuition fee increases to these ratings further jeopardise the sustainability of these institutions.

Finally, we are concerned about the robustness of decisions under the proposed 'light-touch' approach. There is a real danger it could encourage providers to 'cherry-pick' excellent practices that may not be widespread across the whole institution. While this approach may reduce regulatory burden, in my experience, quality mechanisms often vary across different programmes in large providers.

Just as data is not a great proxy for a smaller provider, it is infeasible for a large, multifaculty HEI to provide robust evidence of its approach to curriculum design, assessment, and review in 25 pages or less.

What we need is to better balance the academic autonomy we have with robust external evaluation.

HE institutions have a strong history of working with others to set and maintain standards. The external examining system, whilst not perfect, is and should be the regular boots on the ground quality monitoring, which is impactful for students and maintains our global reputation.  No one, I don't think, is suggesting that TEF panels should work in similar ways to the old QAA HE Review process (although some of my members are keen to have assessors on campus so they can see the magic of what they deliver), but why can’t we lean on externals that take a peek under the quality hood annually more effectively…… We therefore look forward to working with the sector on potential revisions to EEs to ally government fears on their effectiveness.

Furthermore, we have many UK-wide reference points for quality - the UK quality code, the UK professional standards framework to name just two. IT seems bizarre that the regulator would make up lots of new ways to define quality when it would be more efficient to lean on these reference points to measure compliance.

To conclude, while we welcome the move towards a unified quality approach which will make regulation and baseline requirements more coherent and transparent, if there is a desire to use TEF as a measure to restrict provider activities, we need a process that is more secure in accounting for the whole providers approach to quality, and genuinely measures "teaching excellence" without incentivising performative behaviour driven by market-based metrics. The focus must be on robust academic standards and the genuine quality of the student experience.

The exercise must also be proportionate to the provider's size and risk - otherwise the burden stifles innovation and sucks vital resources for delivering the excellent student experience we want to maintain.