Faster routes to degree awarding powers (DAPs). Making it easier for new providers to enter the higher education sector. Levelling the regulatory playing-field. The Government has made significant strides to open-up the higher education sector, and the Higher Education and Research Bill will go further still.


As the Bill progresses through Parliament the proposal to award probationary degree awarding powers hasn’t been without controversy. This has mainly focused on student protection issues such as if an institution goes through the process but doesn’t get these powers confirmed at the end of three years, who will then award the degrees for the students? This is likely to come under closer scrutiny as the Bill moves to the House of Lords.


Probationary degree awarding powers has been framed in the context of a new provider establishing itself and being able to progress rapidly to being able to award its own degrees without having to go to a competitor – the Byron burger argument.


There has been perhaps less attention paid to what existing providers without DAPs might do, whether they will continue down the traditional route or go for probationary powers.


Traditionally institutions have worked with another provider through a validation agreement to accredit their qualifications. This can be a supportive process and help them prepare to apply to receive their own powers and many institutions highly value the relationship with their validator.

However, whilst there are undoubted benefits to this approach, not least in terms of mitigating risk to the sector, there is however the dual cost to the institution of the validation agreement as well as the application fee to QAA to apply for DAPs – something which is becoming ever more expensive.

So in the future will these institutions just decide to go down the probationary DAPs route?


FDAP/TDAP getting more expensive

It is not yet clear whether and what the costs of going down the probationary DAPs route might be, and indeed whether there are other wider risks, such as reputational concerns about a new process. However, whilst the costs and risks of the new process may not yet be known, what is known is that the current QAA DAP process has just become a whole lot more expensive.


The fee to apply for either Foundation or Taught Degree Awarding Powers has more than doubled from £40,000 last year to £90,000 from 2016/17. This could pose real difficulties to institutions wanting to take the next step – not just new alternative providers, but also smaller publicly funded institutions and further education colleges. This at a time when we have also seen this year many sector agencies – membership of whom are either expected or will become mandatory – introducing, or increasing, their minimum subscription rates. Whilst individually each increase might not look like a lot, coupled together these increases can place severe burdens on the smallest institutions.


The increase results from the changes in funding from HEFCE for QAA and the need therefore to move towards to full-cost recovery. This appears to be an unintended consequence of the HEFCE changes to quality assessment and the way in which QAA is funded, and one, presumably, that policy makers wouldn’t have wanted to see. But it does give rise to questions both about the size of the increase and also the warning that institutions involved in the process were given to prepare and budget for the increase.


It also raises the question of whether the increase in the cost will have the (un?)intended consequence of pushing more institutions down the probationary DAPs route so that becomes the usual process used by most institutions.


Is DAP process fit for purpose in the new landscape?

Perhaps there is an expectation that the QAA DAPs process will evolve into that used for probationary DAPs however it should be recognised that many of institutions that are now likely to be applying will be much smaller and/or more specialist and there are therefore questions about whether the current process is fit for that purpose and whether there are ways in which the process could be stream-lined?


The process was clearly designed for much larger and complex institutions where it will take longer to observe all the necessary meetings, need a larger team visiting and so on. It is worth reflecting on whether it might be worth looking again at a more flexible process dependent on the size and complexity of the institution? If the intention of a new probationary degree awarding powers process is to streamline current processes then this will need to be considered.


Whatever the process to receive degree awarding powers it will be important that the process is fit for purpose of the type of providers going through and that the financial cost doesn’t become a barrier to entry.