Green Paper calls in the architects

So it’s goodbye HEFCE and OFFA, hello Office for Students – the Green Paper has announced a big change to architecture of the HE landscape. The new regulator will “empower students, strengthen competition, drive quality, eliminate unnecessary bureaucracy and save taxpayer money” – well it will certainly do the last one because universities are going to pay for it.

Part C (yes really: at 100 pages and in 4 parts this isn’t a short document) of the much-awaited Green Paper Fulfilling Our Potential: Teaching Excellence and Student Choice (even the titles are long) is entitled Simplifying the higher education architecture. It is the go to section for those of us who love thinking about higher education regulation.

The Green Paper presents the new Office for Students as an evolution from HEFCE – “we recognise the strength and expertise in HEFCE, and envisage that the majority of HEFCE’s current functions would transfer to the new regulator.” But there are some big questions being asked here about precisely which functions and how, and by whom, they are carried out.  Firstly, should the Office for Students fund as well as regulate? The Green Paper’s Part D is clear that it won’t fund Research. But on teaching grant there are two options – the Office for Students or BIS. And the function that is up for grabs is described as devising allocation formulas to make the available money meet ministers’ priorities. Clever people, whether sat in Bristol or London, can devise formulas. Someone else, perhaps the SLC, would make the payments.

The argument presented for BIS doing it is that this would enable ministers to strengthen incentives for higher education provision that meets the needs of the economy. Well, perhaps. It is fair enough for ministers to want to ensure they get the intended policy outcomes from whatever teaching grant is left after the 25th November. “Doing” HE policy is clearly government’s job (just as “doing” higher education is institutions’). But there remains an essential place in the middle – the place where the policy intentions of funding interventions get operationalised; where you tweak; where you make things fit for purpose. And if you recognise, as the Green Paper does, HEFCE’s expertise, then you must recognise its depth of knowledge not just in devising formulas but in understanding the impact those formulas will have when translated into actual money, received by institutions to meet particular ends.

There’s a quotation in Anthony King and Ivor Crewe’s excellent The Blunders of our Governments: “No feature of the blunders we have studied stands out more prominently – or more frequently – than the divorce between policy making and implementation.” Over many years, HEFCE’s funding team has been pretty effective at keeping the marriage together.

Secondly, the Green Paper proposes that the Office for Students would have overall responsibility for the quality assurance and TEF functions, and the data function. It asks, should the Office for Students carry out these functions itself or have the power to contract them out to separate bodies? This question places the future of QAA, HESA and perhaps HEA, all of them sector owned bodies, in the balance. The Green Paper is suitably tentative, recognising the “benefits of maintaining a co-regulated approach, the role that other bodies play in supporting wider decisions, for example in providing educational oversight on Tier 4 licence applications, and the UK-wide role”.

When you look at the complicated diagrams depicting the higher education architecture, I can understand the desire to cut the number of bodies wherever you can. To simplify. Or, perhaps, to neaten – I have been through enough machinery of government changes to be skeptical about arguments that bringing functions together necessarily creates simpler and more efficient operations. The co-owned, co-regulated model may look odd at times, but it has worked. And do Conservative ministers really want to storm the commanding heights of higher education quality assurance and statistics by nationalising QAA and HESA?

And then there is that little sting in the tail – the saving of taxpayer money to the tune of around £25m (the running cost budgets for HEFCE and OFFA) by making institutions pay for the privilege of being regulated. This subtle (or sly) variant of the “grants to loans” switch (where will institutions find the money? – from fee income) is presented as being comparable with other regulated sectors and, a common model in higher education. But the sector does, currently, own the bodies like QAA and HESA that it pays for, appoints to their Boards, and can question directly whether the subscription charged is providing value for money. How will that question be put to, and answered by, the Office for Students?

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