Three cheers for Jo Johnson and BIS. Well, let’s say two and a half for now. While I have concerns about some of the details, I’d argue that the White Paper and Technical Consultation and the introduction of a Higher Education and Research Bill provide some reasons to be cheerful.
The first and biggest reason is that Parliament is finally being given the opportunity to debate and vote on regulatory reform for Higher Education. New primary legislation has been essential since the fee changes of 2012. The reasons have been extensively rehearsed: the shift from funding teaching through direct grant to tuition fees backed by loans, the growth in alternative providers, the removal of student number controls and increased competition. HEFCE did its best but its powers derived from its role as majority funder – a role that eroded rapidly until it now funds around 15% of teaching costs. It didn’t fund alternative providers so BIS had to regulate them separately and treat them differently.
It’s a good thing that the regulation of higher education in England is to be given proper Parliamentary scrutiny. And I say that despite the fact there are some Bill clauses that worry me because they suggest BIS are seeking a more directive role for the OfS and the Secretary of State on standards and funding. But it is up to the sector to make the case to MPs and Lords: Higher Education Bills have been improved by Parliament before and no doubt they can be again.
The second reason is the policy intent of much of the White Paper’s content. It is good to have a focus on the quality of teaching and the student experience. For the TEF itself, the criteria for assessment proposed in the technical consultation are pithy statements of what universities ought to deliver and every student should have a right to expect, particularly when they are taking on debt (or, effectively, a higher rate of tax) to pay for it: – of course teaching should provide “effective stimulation and challenge” and encourage students to engage; of course the learning environment should be “enriched by linkages between teaching and scholarship, research or professional practice.” We know that’s what students at GuildHE institutions expect – responsive, informed, career relevant higher education. The HEPI 2015 Student Academic Experience Survey showed that GuildHE students were much more likely than students as a whole to rate “having relevant industry or professional experience” as the most important characteristic of teaching staff. Asked about the overall quality of their course, they were much more likely to be “very satisfied” and were also more likely to rate their teaching staff positively for giving feedback and putting a lot of time into commenting on their work.
And it’s right that the TEF considers the extent to which institutions achieve positive outcomes for students from disadvantaged groups. As was shown in Excellence in Diversity there is “strong evidence that the smaller universities, regionally focused and specialist institutions do particularly well in adding value – in a variety of ways – to the life chances of individuals from less advantaged backgrounds.” Greater transparency on applications and admissions data may not require a new duty imposed through the Bill (I suspect universities would have provided more information voluntarily if asked) but it is still welcome policy.
The link between the TEF and inflation increases in fee and loan caps makes sense too. When the £9000 fee cap was introduced in 2012/13, the BIS spending review assumption was that it would rise by inflation each year. Instead, the price has been held flat for four years. Without an increase to take account of rising teaching costs, the ability of institutions to invest in the quality of the learning experience on offer will, inevitably, decline. When GuildHE responded to the Green Paper consultation, we argued that fees had to rise by inflation at some point and it was fairer for students if those rises were linked to an assessment of quality.
Of course there are still problems with the TEF. The proposals remain proxies for teaching excellence rather than a measure of the thing itself. And the proposal to have a measure of graduates entering highly skilled jobs as one of the core metrics is flawed. BIS are consulting on using employment in Standard Occupational Classification (SOC) groups 1-3 six months after graduation as the measure but it is outdated and hasn’t kept pace with the development of a range of graduate careers. It is particularly problematic for careers in the creative industries – a sector where career trajectories are typically longer and one where serial and parallel portfolio careers are the norm.
Another reason for deducting half a cheer is the lack of any detail behind the radical proposal to allow “high quality” new providers to offer their own degrees on a probationary basis. The White Paper says such providers won’t have to “demonstrate a lengthy track record or meet specific and separate DAPs criteria” but “will be subject to “strong quality checks and close monitoring”. However, it provides no information about what those checks will be and how they will be conducted. I understand BIS intend to provide more detail during the passage of the Bill. But at the moment, there is simply no basis to judge how, and how well, the potential risks of this policy to the student interest and the international reputation of UK higher education will be managed.
So despite the concerns – and to misquote the great Ian Dury – Reasons to be cheerful, one, two, two and a half.