The desire to trim the fat of administrative burden can sometimes cut to the bone.

We welcome the ambition to eliminate duplication and, where appropriate rationalise the current Quality Code, and to make the Quality Code more accessible. However without more detail, particularly about what the “advice and guidance” will look like, the proposed Quality Code does look very thin. The current Code provides institutions with an important reference point on quality and standards in the sector – particularly helpful for new providers – and this should not be lost.

There are two key features that we believe must be considered – how we maintain a UK-wide higher education system and the role of enhancement and students within this.

UK-wide higher education

The UK has a hard-earned track record for excellent quality higher education, and this UK dimension must not be lost. The Quality Code is the glue that holds the UK higher education sector together and must remain a UK-wide document or risk damaging our international reputation.

We are currently in a dangerous situation with two different organisations consulting on the same expectations relating to quality and standards. The UK Standing Committee on Quality Assessment, through the QAA, is currently consulting on the wording of four high level expectations that form part of the revised Quality Code. These expectations are also included, with only minor differences, in the conditions of registration in the OfS consultation (conditions B1, B2, C1, C2).

There is a real danger – given the differing respondents with the former consultation being UK-wide and the latter consultation England-only – that these expectations might diverge. Indeed paragraph 17 of the OfS consultation explicitly allows for the OfS to decide whether the “revised Code is suitable” and if not to “task the DQB to work with the sector to design and implement a Quality Review system that is underpinned by the quality and standards initial registration conditions and behaviours, rather than the Code”.

We would strongly encourage the OfS to abide by the outcomes of the UKSCQA consultation to prevent a loss of the UK-wide nature of our higher education system and the resulting international confusion and loss of reputation.


There are also wider questions with the regulatory approach of the proposed Quality Code. In particular it positions enhancement as a supplementary practice rather than an expectation or core practice. The OfS consultation takes this further expecting market forces to be the key driver for institutions to enhance their provision. GuildHE argues that enhancement and student partnership are essential characteristics of the higher education in the UK and we shouldn’t be simply be moving towards a position of lowest common denominators for the baseline expectations, particularly when the market incentives available aren’t necessarily up to the job.

As highlighted in the recent NAO report “In principle, university rankings and league tables encourage providers to offer high quality education to attract students, but in practice these incentives appear weak” before going on to comment that even if the OfS intends to be a market regulator “that will help to drive competition in the interest of students…the OfS will not have formal competition enforcement powers, and will therefore need to draw on the expertise of the Competition and Markets Authority.”

Students as partners

As I’ve blogged elsewhere with the Chair of the GuildHE Students’ Union Network, engaging students as partners in their education is an essential feature of UK higher education and as such should firmly embedding in the expectations and core practices of the new Quality Code.

Student engagement is an essential component of the character of UK higher education – it reflects “higher learning” and co-production, and it’s something the UK has built and is envied for – as such we ought to expect it in all providers of HE.


This does not, however, mean we should throw out the proposals for the new Quality Code and start again. The risks of the OfS simply going off in a different direction are too great. It should also be noted that many of the revisions are to be welcomed, and would be enhanced with more clarity about what the Advice and Guidance will look like, amending the expectations to reflect enhancement and student partnership, as well as tweaking of the some of the wording in the proposed Quality Code.

The revised Code, if seen as a short summary document that sits atop a more detailed Quality Code would be a welcome addition that would make the Code more accessible to students, employers, governors and others.

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