A critical moment for the quality debate

A battle for the future of quality assurance in UK higher education is underway. HEFCE has been reviewing the quality system and a second stage of their consultation is expected to be published soon.

I have seen a draft of the consultation document and the sector has been extensively briefed by HEFCE about the planned direction of travel, causing a frenzy of debate – much of which has been briefed to me by multiple senior sources. However none of the key players would talk to me on the record.

The plan – as far as we know

The plan envisages a new quality regime built on governance in HE – making university governing bodies more explicitly accountable for their own institutions’ quality, an increase of use of metrics to drive improvements inside universities and a substantially beefed up external examiner system. But no institutional review as we knew it – saving universities some part of an estimated £1bn that they collectively spend on managing the bureaucracy of QAA’s external visits, and saving HEFCE the cash that it spends on commissioning QAA to carry out HEFCE’s statutory duty to assure quality in English HE.

The plan – as it stands – does envisage a sort of audit to be carried out every five years as part of HEFCE’s assurance review which already takes place every five years – a health check to ensure the evidence used by the governing body in its assessment of quality is up to scratch. Details of how this will work are patchy, but it certainly doesn’t appear to need the involvement of any other agency separate to HEFCE, who would only need minor alterations to its own existing assurance review guidance to implement.

The timing and politics

The timing of all this has raised eyebrows. As I reported back in October, HEFCE put their quality work out to tender which led to furious speculation that they ultimately intended to either bring the work in-house, or give it to someone other than QAA. HEFCE’s mission – in lieu of having new powers that would flow from a higher education bill (there’s one drafted and ready to go that includes the measures needed, but awaits the political will to take forward), has been to establish itself as the single, indisputable regulator of English HE. The outsourcing of a major part of this responsibility – quality assurance – always looked vulnerable in the new landscape. Particularly given the economic context – HEFCE spends c.£5m per year on QAA and BIS will need to offer up substantial savings to the Treasury through next year’s spending review.

So HEFCE – getting ahead of economic and political pressures – has been quietly reshaping the landscape. Some see this is a power grab – HEFCE consolidating its position quickly before a new government fully beds in.

For others, it’s merely an overdue rationalisation of the regulatory system and we shouldn’t get misty-eyed about contractors that HEFCE choose to bring in to do its work. Most had assumed that HEFCE was going to be taking on more powers anyway soon – if not through legislation, then through the sort of shift that’s being talked about here, in consultation with the sector.

But what’s potentially changing is much more interesting and important than where quality sits: in-house at HEFCE, or outsourced to QAA being the two most feasible options. And yet, sector turf wars usually dominate discussions about quality.

The reaction

Feelings run deepest at QAA who have at HEFCE’s behest been assuring quality in the sector since 1997 and who also have an established international reputation in their own right – not to mention years of understanding of higher education quality and a treasure-trove of good practice and institutional memory. The fear amongst many of their staff now is that all of this – along with their jobs – are now at risk. And who could blame them? They gather in Leeds on Wednesday night for their annual conference in full knowledge of the measures under scrutiny and with uncertainty about their future at the forefront of their minds.

For universities, institutional review was always complained about as too-bureaucratic, too expensive and too heavy-handed. A million miles away from the hated subject review developed in earlier, more muddled days, sector leaders would not miss having to service what they still view as an overly complicated and onerous mechanism.

But their mistake would be to miss the reputational risks associated with losing it all. Yes it’s expensive and arguably onerous, but the QAA seal of approval is known around the world as a mark of quality – literally – and in a time when new entrants to the market are proliferating, the traditional part of the sector should be looking to protect its reputation at all costs.

Alternative providers

Recent criticisms by the Public Accounts Committee and others about the proliferation of student numbers at private colleges give rise to many complicated questions of regulation and funding in this part of the sector. But few would argue that a lighter touch is what’s called for here. After the sale of University of Law and its assets last week, fresh concerns about the strength of the regulatory regime were highlighted, bringing all these questions of regulation in to sharp relief.

It’s unknown how HEFCE’s mooted plans would touch alternative providers over whom they have little sway, without being granted new powers. Those providers already signed up to QAA embrace their reviews because they are a prime exercise in both improving practice and getting the ultimate seal of approval – the gold-plated quality mark that matters so much more for newer entrants to the market.

So it’s likely that those already in the system would cooperate with an inspectorate built out of HEFCE if one was to be created – but for how long? – and what about those that didn’t want to play the game – the sharks out there more interested in cynically using the student loan system to power growth in numbers at any cost? Is HEFCE up for the battles it could face in the legal system if it tried to compel more-unfriendly providers to change their game?

One of the great – but curious – aspects of UK HE is that everyone in the sector basically operates with a sense of integrity and propriety. Sure, people game the system to gain advantage and poor, sometimes disastrous, decisions are made and there are always cases of incompetence – but everyone has good intentions for their institutions, staff and students, even when they’re getting things wrong. What’s new is that there are people in the system that now come from an altogether different place. They will go much further than gaming the system in pursuit of money and power and will casually disregard established principles of behaviour to benefit themselves. QAA along with the past regulatory regime probably wasn’t ready to deal with this previously-alien approach, and the sector in general still hasn’t changed its behaviour much in a way that recognises the altered landscape.

But given that the whole sector’s reputation is at risk, it is absolutely essential that whatever future quality regime is put in place, it deals proportionally with different parts of the sector and is backed up by the appropriate powers to do so.

Governance and ownership

For traditional providers – their governors are theoretically accountable to HEFCE and it is via this mechanism that the new regime could work. Highlighting as it does the lack of more robust levers needed by a single regulator, it also comes at a time when the perception of governance in HE is probably at its weakest for quite some time.

There have been multiple high-profile casualties of governance failings recently, and countless private reports of senior teams at war with their governing bodies. And an avalanche of individual decisions made by governing bodies have left sector experts scratching their heads. It has become de rigueur in the sector to talk about how governance of institutions isn’t working quite as well as it should. And there are scant proposals on the table in England for properly improving it. Placing even greater responsibility in to this sphere of influence, already so patchy and inconsistent, comes with further risks.

And for the sector which has previously ‘owned’ its quality regime, questions will remain about accountability and influence in the system. Vice chancellors through UUK and GuildHE representing the sector, have been able to greatly influence the direction of quality assurance over the past few years – and plenty has been up for debate as the regime itself has been subject to continuous improvement. The sector sits on QAA’s board and advise on all aspects of policy and practice – a quiet but powerful mechanism that has ensured that the regime has been the servant of universities in so far as possible – and the more outlandish ideas of ministers are moderated through co-regulation. As funder, HEFCE has played an equally important role and the past changes – and the debates around them – have been civilised, business-like and largely out of public view.

Without QAA and the principle of ownership in play, the sector could be ceding some power and influence over its quality and regulatory regime. It certainly puts the idea of co-regulation up for debate. There are plenty that would argue this is utterly desirable, if not essential for a newly-designed regulatory regime. But universities should consider if this direction will ultimately serve their interests. HEFCE might seem like a friendly ally and partner today, but it’s not hard to see how future changes of government, funding and policy could frame the organisation in an altogether different light. Co-regulation and ownership – though producing an arguably flawed result in the form of today’s system – might one day look far more preferable than what follows it.

Devolution

Scotland is doing something completely different, but Wales would be caught up in England’s plans. However it would not surprise me if given the choice, Wales would choose to opt out of the English master-plan and go their own way. Faint rumblings along those lines can already be heard and I would expect them grow louder as the consultation progresses. Good news for Welsh quality wonks perhaps, but dim news for the UK as a whole. Differing regulatory regimes around the UK would lead to unintended consequences too numerous to list – but above all will likely weaken UK HE as a whole, as its domestic and international partners will find it increasingly harder do business with an ever more stratified sector.

Northern Ireland too will be caught in the wave of changes, but their sector is in the throes of a grave funding crisis which overrides everything else. It is unlikely that they want to make life any harder for themselves at this stage and so are unlikely to deviate from the English (and possibly Welsh) plan.

A teaching REF?

There has been much talk of a teaching excellence framework or ‘teaching REF’ on its way – it was referenced in the Conservative’s manifesto before the election and its likely to feature in this government’s policy in some form. However it is noticeable by its absence from the quality debate. Although no one really knows how this framework will work (indeed it hasn’t yet been developed) it appears as if it might end up sitting to one side of the new quality assurance regime. Perhaps they are destined to connect one day, but for now they exist apart in policy and in the design of the new systems – quality having had a significant head-start. Expect to hear more about the nascent framework – but not any time soon – and not in HEFCE’s upcoming consultation on quality.

When the HEFCE consultation is finally published, we’ll look in depth at its different proposals, weighing up the merits of the different ideas on the table to help the sector as it prepares to respond to one of the most important consultations to come before it in recent years.

11 thoughts on “A critical moment for the quality debate”

  1. Suzanne says:

    Big funding cuts often lead to radical reform borne out of necessity- the impact of which won’t be understood for many years. Arguably, institutional review needs overhaul but whether HEFCE – who’s response to the government request to monitor quality post-SNC was lack-lustre to say the least- is up for the job, I’m not sure.

  2. Andrew says:

    The current abuse of the word ‘quality’ is an embarrassment that we live with, fearing a return of something like the teaching quality assessment. If you were a member of the public, what would you think ‘quality’ refers to?

  3. dkernohan says:

    Worth remembering that QAA has statutory and quasi-statutory roles around DAPs and course designation. So even given this scenario the QAA is far from over..

    1. mpicken57 says:

      I had understood that the QAA was an independent company/charity and that it carried out advisory work on behalf of others who have the “statutory and quasi-statutory roles”, ie HEFCE, Privy Council, DBIS and the Home Office. Legally, it is more akin to a consultancy company than a statutory body, and therefore its role is relatively easy to dispose of.

      The most important statutory responsibility, that for the “assessment of quality of education provided by institutions”, is vested in the HEFCs directly under s70 of the 1992 Act, and for the first five years HEFCE carried out this work itself, through their own staff organised in a Quality Assessment Division. The QAA did not even exist then – the HE Quality Council was set up by institutions to support Quality Audit (among other things), a non-statutory activity covered in the 1991 White Paper that preceded the 1992 Act. HEQC was dissolved to give the QAA a wider advisory role and a chance to undertake Quality Assessment on behalf of the HEFCs.

  4. DC says:

    Good post Mark. Thank you for such a comprehensive overview and for flagging the transnational consequences for higher education institutions of devaluing the reputation for “quality” that QAA has helped them to build up over the decades. Continuing on the transnational theme, I have concerns that HEFCE seems to set no store on the standing QAA has achieved across the European Higher Education Area as a leading voice and on the Bologna process – I don’t see HEFCE being able to achieve such standing any time soon. And if proposals like those reportedly put forward by HEFCE are adopted, will that mean that the UK will lose its influence in the Bologna process?

    Nothing I have seen to date (including your post, Mark) seems to have mentioned the UK Quality Code or the Framework for Higher Education Qualifications in the context of the HEFCE proposals. Is that an oversight? Or because it’s too geeky even for WonkHe subscribers? It’s arguable that the UKQCHE in its present, overbearingly prescriptive form needs to be heavily modified; however, until reports of the HEFCE proposals began to surface, the value of some sector-wide, UK-wide, accepted set of reference points for curriculum management has seemed inarguable. Are we really seeing the possibility that the development of these reference points in fulfilment of a key part of the Dearing proposals will be jettisoned?

    Suzanne mentions the need to overhaul institutional review which in its latest incarnation as Higher Education Review is crushingly burdensome for small providers and too superficial for large providers to be dependable. I wonder how many of the features of HER and its predecessor were introduced by QAA at the behest of HEFCE? Suzanne also mentions

  5. DC says:

    Sorry for the interruption

    … unintended consequences. Maybe a period for reflection by HEFCE would be a good idea….

  6. Mark Leach says:

    Yes there’s stuff about the quality code etc and no, nothing is too geeky for Wonkhe! But I am reluctant to go in to detail about these things when what’s circulating is still in draft and might still change. I will return to all the proposals in great detail after they are published.

  7. mpicken57 says:

    I sympathise with the idea that QAA has a lot more expertise than HEFCE. However, now that the vast majority of funding is routed through fees, HEFCE faces either being turned into a ‘super-regulator’ or being wound up. If economy is the name of the game, then it would be more logical for all the regulatory responsibilities for all post-compulsory education to be vested in one accountable and representative body than across multiple agencies. However I doubt very much that is going to happen.

  8. lizmorrish says:

    I was wondering what happened to the idea floated a while ago of the HEA going for the QA tender?

    1. Paul Kleiman says:

      Based on recent evidence, the HEA sees itself (or would certainly like to see itself) playing a central role in any TEF. Remember, its current funding runs out next year.

  9. “making university governing bodies more explicitly accountable for their own institutions’ quality”. Remember the BBC Governors and the Hutton Report? He basically knifed any system which involved the Governors’ dual role as champions and regulators, for good reason.

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