Alex Bols, Deputy CEO gave a speech at the Quality Strategy Network Conference on the 1st October. You can read the full transcript of the speech, below:



Our members reflect the diversity of the higher education (HE) sector: from multi-faculty universities to specialist institutions. Our membership includes ‘publicly-funded’ universities and colleges as well as a number of private HE providers.

GuildHE is one of the two officially recognised representative bodies – along with Universities UK – and between us we represent the “sector”, and as such we have a central role in many sector bodies – as company members, which includes bodies such as the HEA, HESA and of course the QAA, and so the discussions over the last year or so have been particularly pertinent.

Over the last few months we have held a number of round-table discussions with members about the HEFCE QA consultation and the TEF as well as gathering evidence from institutions and so I hope that my comments resonate with many of the discussions you’ve been having and are reflective of a wider perspective than just my own.


I want to use this speech today to critique the current proposals – but more than that to try and break the cozy consensus view that HEFCE seem to be suggesting that the sector is in complete agreement with the proposals, and I think that the article in the Times Higher this morning reiterates how far we are from an agreed position.

I personally have quite real concerns about the proposals, and having spoken to many people across the sector and read a number of consultation responses – from a wide range of organisations – know that I am not alone. We cannot simply sit back and let our concerns with the proposals be swept under the carpet.

These are concerns both about the practical implementation of the proposals but also extend to a much more fundamental level. The quality landscape has been carefully developed over a number of years and simply removing several key aspects including independent, cyclical, external peer review and large parts of the Quality Code would risk destabilising the whole quality landscape. Whilst I don’t disagree with the principle of strengthening particular aspects of the current landscape, such as external examining and institutional governance, I believe that they alone would not withstand the anticipated level of scrutiny if they became the central features of a new system.

When I think about a future QA system there a number of key features that should be central:

• The UK has an international reputation for excellence and the proposals have been very cavalier towards the risks of moving away from a UK-wide framework – let me restate the need for the new QA system to include the whole of the UK…including Scotland…and more needs to be done to ensure this outcome

• Secondly, the future QA system should be based on the principle of independent peer-review and respect institutional autonomy

• Thirdly, it should both protect the student interest and have student engagement  at its heart

• And finally there should be a single framework – but one that is flexible enough to recognise the increasing institutional diversity that characterises the sector

Over the next 15 minutes or so I will look at four key elements of the proposals in more detail before I end by making some comments about the Teaching Excellence Framework.

In particular I want to focus on the proposals relating to:

  • the external examining system
  • institutional governance
  • the removal of institutional audit
  • and the role of the QAA

The other point that I wanted to challenge is the notion that the proposed system would actually result in cost-savings for institutions. This seems to be mirage on the horizon that we’re all walking towards but disappears the closer it gets. It is important that any new QA system is both proportionate and does not increase burden but I’m yet to be convinced that the proposals achieve this.

External Examiners

So I would like to start with the proposals surrounding the external examining system – which have the feeling of deja’vu – didn’t we discuss many of these ideas a couple of years ago!

Now – as then – there were concerns that the proposals seem to run counter to the principle of institutional autonomy. The proposals place too great a regulatory dependence on the external examining system, including the false expectation that the external examining system could support uniformity of student outcome standards – which clearly it cannot.

As the QSN response highlights, the sector has reflected on the external examining system and its shortcomings in recent years, and we value the role of externals to support standards but they are – and should remain – just one element in the quality jigsaw.

Many institutions that I’ve spoken to already have robust processes for recruiting, appointing and training external examiners, although the consistency in this regard could clearly be enhanced and indeed there may be a role for national support. This has already been enriched by the amended section of the Quality Code, but the research into external examiners by the HEA was held back by the fact that so few institutions had been reviewed since these revisions to the Code and so there was limited evidence of the impact of the revisions.

But there is little evidence to suggest that a national register would effectively counter the concerns that there are with the current system, and indeed the sector, whilst taking on board most of the recommendations of the Finch Review rejected the idea of a register only four years ago.

There are real concerns that a register would introduce unnecessary bureaucratic processes such as accreditation and training to join a register that might deter existing senior academics and industry professionals as well as provoking concern that it could develop to include central allocation. There are also more practical details about how to ensure that it is simple enough to enable institutions to be able to nominate and appoint people to the register – whilst at the same time being rigorous enough to allay Ministerial concerns. There are also concerns about how to ensure that it is flexible enough to incorporate different skills and knowledge required from professional and industry experts and that there is a wide enough coverage for those in small or more specialist discipline areas.

There was a suggestion at our round-table that perhaps a less bureaucratic “list” that is populated by input from the HEIs, might seem a more appropriate starting point which institutions can easily add to, rather than a centrally-run “register” – indeed I have heard comment that the QAA used to have a public list of reviewers and their affiliations, which was relatively helpful – but we would of course need to consider how the list would be maintained and updated – including how external examiners would remain in “good standing” and indeed how institutions could log any rogue examiners.

The external examining system plays a key role is assessing standards and can be enhanced and we look forward to working with Universities UK and others to help develop proposals to further strengthen the external examining system as proposed in the consultation, but our starting point shouldn’t be a register.


Secondly, I wanted to move on to consider the proposals surrounding strengthening institutional governance, they rightly recognise the primacy of institutional autonomy and point to an area that institutions could usefully focus more emphasis, when I think about the governing body that I sit on we could certainly have a much clearer understanding of how the institution manages its quality and standards.

But the key point that has come out strongly in discussions I’ve had is the important role of the dual governance system based on both academic governance (through academic board/senate etc.) and the governance of the institution (provided through Board of Governors, Council etc.). This is seen as one of the strengths of the UK HE system and we wouldn’t want to destabilise this delicate balance.

The governing body should reassure itself more that the quality management processes are being carried out but the governing body shouldn’t be trying to actually manage academic standards themselves – which the consultation seemed to imply in various places. It is worth noting that the revised CUC Guidance in this area is still relatively new and will take more time to embed and we should review how this is being implemented.

On a more practical level there are real questions as to whether governing bodies currently have the required skillset to be able to do this effectively and in order to be able to do this whether it might result in a less diverse governing body with more governors with an HE background which could impact on either the size of the governing body or a reduction in those with business and financial backgrounds.

It is also interesting that the reforms relating to institutional governance are being framed as bringing externality and independence, when clearly the governing body can’t be independent of itself!

It is likely that governors would need to bring in external consultants to provide them with suitable independent assurance, which might end up not being any cheaper than the current costs, whilst losing the peer-review dimension.

Institutional Review

When reading the Times Higher article it suggesting that there was slightly more agreement about the removal of institutional review – or as the consultation put it, “repeatedly externally retesting against the baseline requirements”.

My initial response is that Institutional Review is much more than just retesting against baseline and provides a helpful opportunity for self-reflection and enhancement – or at least when I look North of the border it does and could here with some tweaks – but it also provides a real vehicle for student engagement. But also that there could be significant impact on the international reputation and external perception by removing this key element – especially if we’re also saying that the other elements of the proposals won’t do the job on their own.

It was perhaps difficult to answer this question in the consultation because of the links with the TEF – the Minister has spoken about his belief in the need for external review – and that the two consultation processes haven’t been completely aligned, so we were answering the HEFCE question without knowing what the Minister will propose. My current concern is that since TEF1 is likely to be a relatively light touch, metrics based process the external review element may not have been considered before decisions have to be taken in relation to the future QA system and so we need to ensure that these decisions are taken in tandem.

Role of the QAA

I also wanted to say a few words about the QAA – which was noticeable by its absence in the HEFCE consultation. I think we all know some of the difficulties of the QAA, not least the way in which it has felt increasingly in recent years that Review has become tick-box and mechanistic looking at the 100+ indicators but we should also recognise that QAA has changed significantly over the last 20 years and can do so in the future.

It was noticeable in his speech earlier in the Summer that the Minister, Jo Johnson, stressed the continuing importance of external review by “an independent quality body from within the existing landscape as part of the TEF” and went on to refer to the QAA in his next breath.

It is worth emphasising that the QAA is co-owned by the HE Sector through the representative bodies GuildHE and UniversitiesUK. This co-ownership of the QAA means that the sector is able to help direct its work and can also play a key role in re-shaping it to be fit for the future, something that would be much harder in a Government-controlled body. When people talk about removing the QAA I would reply be careful what you wish for, the QAA may not be perfect but we have the power to change it.

Alternative Providers

I also wanted to say a few words about private providers – as I mentioned we have a number in membership and I have been struck by just how good they are and that some of them have been around for many years.

It is worth thinking about how they are treated once they have passed through the regulatory gateway – which needs to be high enough to provide real assurance – but once they have passed through the gateway whether they need to have probationary periods, and fixed DAP periods, and so on or whether they should just be dealt through the QA system tackling issues as they arise and monitoring in a similar way to other institutions. If we think they’re good enough we should treat them as such, although it is helpful to incorporate other triggers for all institutions requiring closer scrutiny such as change of institutional ownership, or possibly even significant change in institutional governance.

However as more institutions will want to enter the sector some may also want to exit, and so there needs to be a process to allow this in an orderly way that protects the student interest and this is likely to need legislation and may feature in the Green Paper.

But one issue that I raised back in a blog back in April is whether there is need for a new validating body to enable new institutions to enter the sector – something that Jo Johnson put rather more pithily when he referred to Byron having go to McDonalds for accreditation.

I believe that we must continue to ensure that we enable innovation and allow new entrants into higher education and so there needs to be a clear route into the market and regulation shouldn’t restrict entry just because an institution is new.

Currently new providers often have their courses validated by existing universities, however, I have heard from several institutions that in an uncapped, increasingly competitive higher education sector, some validating institutions are less keen for their partners to develop new courses – it’s just not in their commercial interest for them to do so.

As these partnerships have the potential to become increasingly tense it is worth considering whether there needs to be an alternative route to delivering higher education from the university partnership model – maybe something similar to the old CNAA?

If we did go down this route there would be a number of questions to consider such as how we prevent the return of a prestige differential that would negatively impact on an institution’s brand. We would also need to consider how this body maintains quality, it would need to be more than just a paper exercise. But there is a place for this alongside the university validation route.


Finally I just wanted to say a few words about the Teaching Excellence Framework. There has been a lot of discussion about this since the Conservative Manifesto was published – which as we know was written, at least in part, by Jo Johnson. This has developed since the General Election and the Minister has made this one of his top priorities and has spoken about the need to raise the profile of teaching within institutions.

The Chancellor’s announcement in the Summer Budget back in July that institutions will be able to raise their fees by inflation based on the results of the TEF has raised the profile of this issue still further, and also set a challenging timescale by saying that institutions will be able to raise fees from 2017/18 meaning that there will need to be assessment in 2016 in order to be able to let prospective students know their fee rate. There has been much speculation that the timescale implies that the TEF is likely to evolve with an initial TEF likely to be fairly simple, based on existing data, with the BIS Green Paper expected in the Autumn. This more simple “TEF1” is likely to evolve into TEF2 as ideas about how to measure teaching excellence are further elaborated and information comes out of the learning gain pilots.

As we know BIS has been gathering evidence from institutions over the Summer, and the key message that we have been emphasising is that any TEF must recognise the diversity of the institutions, and also subject disciplines, which would highlight the need for data to be benchmarked based on the students and regional differences and ideally also with institutions being able to give a narrative about their institutional perspectives.

In recent weeks there has been concern about the impact on the reputation of the UK higher education system if there is a high pass rate with large numbers being perceived as failing, the Department seems to have heard this – with various options being mentioned such as the Athena Swan Gold, Silver, Bronze one model that’s been suggested, although the recognition that QA reforms and the TEF should be brought together might provide a helpful way of placing the TEF on top of QA processes and so setting an initial pass rate as having gone through a QAA review.

But this issue has been evolving at an incredibly rapid rate and they’ll be facing a consultation on this as part of the Green Paper when BIS publish this.


It is a cliché to say that we live in interesting times but the range of issues relating to quality that are being considered at the moment is quite unprecedented, although nonetheless quite exciting and if we get it right we have a real chance to strengthen our position as one of the world’s best higher education system.

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