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How will OfS do policy when its levers are broken?

As the development of the Office for Students gathered pace last year, figures around its nascent leadership were thinking about the new regulator’s role in policy. The thinking being, that apart from something it has clear mandate in such as access and participation, OfS isn’t to “do” policy.

It’s a cause for concern. You can’t not do policy. Whether the distinction is about developing or implementing policy, the fact is that policy still exists, it just isn’t called policy and can’t be influenced in the same way.

For example, Ofsted doesn’t officially develop policy, but does pro-actively influence it, independent of government (to varying degrees at different times and usually down to individual personalities), through its unique position, expertise and data. Its ‘state of the nation’ type reports have been hugely influential at key points.

Defining policy

What is policy? A good dictionary will tell you that it is “a course or principle of action adopted or proposed by an organisation or individual” – rather than decisions themselves policy represents the framework, conceptualisation and principle that underpins the way that decisions are made.

A quick example – imagine the mess that would ensue if every institution needed explicit approval from HEFCE to appoint academic staff? Instead of this (which happens in a sense in France…), we have policies of institutional autonomy and academic freedom, that means institutions can make these decisions for themselves.

But what if we wanted to change this – what if a university chose to appoint Katie Hopkins to a joint chair in ethics and pharmacology? There’d be a press outcry; there’d be lobbying and questions in parliament. But in stepping in to demand that the appointment was rescinded, a sector body or minister would be going against policy.

This may (or may not) be justified in this intentionally extreme example – but once the policy is changed, it becomes easier to have academics removed for other reasons, perhaps for disagreeing with the government’s stance on immigration, or for promoting pro-climate change ideologies. The precedent has been set.

From this, you might surmise that being the body or person that sets policy would put one in a position of no little power. And for a body to avowedly refuse this role suggests a couple of worrying developments.

Don’t throw your tools away

A policy is a tool that helps you achieve a goal. If you put down your tools, you put down the main means that you have to progress towards your goal. You are abandoning your strategy to chance.

HEFCE, historically, has been pretty good at setting policy transparently and openly. It publishes its board minutes, consults widely with the sector, and even where decisions are made that go against a consensus, are clear around its rationale for doing so. The old funding council was set up as a “buffer body” – a term never used in legislation, but widely employed to describe the way that HEFCE sits between government and the sector, and protects each from the worst excesses of the other.

Ministers, in contrast, are not so great at policy. With two recent examples of a minister highly engaged with the sector in developing policy (David Willetts, early Jo Johnson), you could be excused for thinking that this is a little harsh – even if you are less than thrilled at the outcome. But a counter-example (late Jo Johnson) chasing headlines and playing to the party by pursuing populist issues (free speech, grade inflation) rather than important ones (alternative provider regulation, mental health) demonstrates what has been the situation since government first took an active policy and funding interest in universities, way back in the 1910s.

The minister and the market

So – when OfS suggest that it doesn’t “do” policy – one possibility is that it sees policy as the responsibility of the minister. As above, we’ve been lucky in the recent past (in terms of policymaking – I’m not commenting on the rationale underpinning the policies), but there is no reason to suspect we would continue to be as lucky, however well Sam Gyimah may shape-up to be.

HEFCE’s “buffer” role helped to ease some of the pain of swingeing cuts in the 80s and 90s, managed (mostly) successfully the boom years of the 00s, and protected the interests of students, researchers and institutions. Policy coming from ministerial fiat was thoughtfully translated into interventions that made sense, and either achieved stated goals or were at least not actively harmful. Getting rid of this filter is not good for the sector, for either new market entrants or ancient institutions.

The other possibility is a little scarier. The idea that the sector will, effectively, administer itself – steered by the “invisible hand” from first-year undergraduate economics – is (let us not mince words) a technocratic fantasy. Education, and higher education, in particular, is not a typical “market good”. If we rely on the widely discredited concept of “homo-economicus”, largely acted out by a single-generation of 18-year-olds and their families, we’ll be in big trouble.

The invisible hand only moves in one direction

However central a role you hope market forces will play, tools and levers should be in place to protect the interests of students, of academics and of the wider nation. They also have to balance the interests of past, present and future stakeholders. And this is before we consider the idea of intervention in the system for strategic goals – skills and R&D expansion linked to the industrial strategy, addressing local or economic needs, improving social mobility, or greater student choice.

The latter isn’t creeping statism, it’s a basic assumption that a country which is spending spiralling billions on higher education, in the short and long term, would want to have some means of ensuring that it gets what it wants out of it – even if it can’t quite decide what it needs and keeps changing its mind.

The technocratic argument would be that the use of good quality data means decisions are made objectively. Given sufficient data – goes the argument common in the wilder spheres of edtech – decisions are just algorithms, and can be settled mathematically. If your indicator is at 0.9 everything is in order. If it drops below 0.8, close a university.

This is firstly an abdication of leadership. Richard Hall and Joss Winn argued on Wonkhe recently that we tend to obsess over the value of leadership in HE – but I would suggest that we are in far more danger of fetishising output data. Such statistics are an important part of decision-making, but to rely entirely on them is dangerously reductive. Professional judgement and experience have to have to be in the driving seat, with different forms of evidence subordinated to informing decisions.

But secondly, this is an abdication of humanity. We learn as we travel through life that situations that appear the same superficially can turn out to have hugely different causes, and need hugely different interventions. More data can help, but sometimes listening to the voices of those involved adds far more.

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