GuildHE has submitted its comprehensive response to the Office for Students (OfS) consultation on the reforms to quality regulation, which proposes integrating the existing B condition assessments with the Teaching Excellence Framework (TEF).
While we are broadly supportive of the principle of integration to reduce confusion and duplication, our response highlights several critical areas where further consideration is needed to ensure the new system is robust, fair, and truly effective for all providers.
Our top three areas of focus are:
- Administrative Burden and Robust Judgements: We are concerned that the proposed approach, particularly the 25-page limit for provider submissions, is insufficient to demonstrate a provider's widespread approach to academic provision across its whole offer. While aiming for a reduction in regulatory complexity, the substantial challenge for institutions to provide secure, comprehensive evidence for all integrated B conditions remains. We urge the OfS to ensure the right balance is struck between minimising commentary and evidence, and enabling secure, transparent judgements, especially given the suggested penalties.
- Critique of Metrics and Extrinsic Values: We fundamentally disagree that this iteration of the TEF should continue to rely heavily on market-based, extrinsic values and metrics, such as graduate salary, as the primary indicators of academic quality. We cite extensive academic literature and research, including from the Institute for Fiscal Studies (IFS), which suggests salary is linked more unilaterally to prior attainment, social class, and employer prestige than it is to teaching quality.
We believe the TEF is in danger of "counting what it can measure, rather than measuring what counts".
Dr Kate Wicklow, Director of Policy and Strategy
3. Fairness for the diversity of HE providers in the sector: The data-heavy approach of the TEF disproportionately disadvantages smaller providers due to their small cohorts, lower and lower data confidence. We strongly urge the OfS to re-evaluate the balance between data and contextual commentary to ensure fairness for all registered providers, regardless of size. Suggestions to mitigate this include considering on-site visits in the methodology or providing a mandatory universal template for submissions to increase parity.
We look forward to continuing our discussions with the OfS on stage two of this process to ensure the reformed quality assessment system is fit for purpose and upholds the reputation of English higher education.
Read the full consultation response.