The UK Quality Assurance system has undergone significant change over the last few years but with the recent consultation on the Quality Code (UK-wide) and Regulatory Framework (England-only) it seems we are even further from the cyclical, risk-based review methodology that we used to know.
Changing with the times…
HEFCE’s Quality Assessment model had moved towards a more outcomes-based process, but this sat awkwardly beside a similar exercise driven by DfE: the TEF. Both collect similar data in different ways and are interconnected at many points. Yet, with the October announcement of the freeze on tuition fees (at £9,250), the main incentive for institutions to enter the TEF was lost.
The new regulatory framework proposes that TEF entry is a condition for all Approved providers on the new register. This causes some confusion – as previously Quality Assessment was a prerequisite to enter TEF, but now the TEF will be a prerequisite to join a Quality-assessed HE system. So which comes first, the proverbial chicken or the egg?
It seems OfS has a solution – they aren’t too attached to the current model of Quality Assessment. In paragraph 37 of the regulatory framework it states:
“…the OfS will not undertake routine reassessment of providers, either along the lines of Annual Provider Review or of annual redesignation. Instead its approach will use data and intelligence to identify where further scrutiny is needed to combat the risks outlined above.”
Despite launching the Quality Code consultation just a week before, OfS are prepared to start again if it doesn’t go right. Although the intention is to use it to form the basis of the new quality review method, OfS will ask the Designated Quality Body (DQB) to design a new quality review based on “the quality and standards initial registration conditions and behaviours, rather than the Code” if it isn’t deemed to be suitable. With ALL of the consultation in November, it would be disappointing if the Quality Code proved fruitless, particularly for the nations who could be left with a Code that is no longer UK-wide.
Grade inflation – a silver bullet?
Wonkhe covered Jo Johnson’s concern with grade inflation when he announced a supplementary metric for TEF in the Year three specification. It isn’t a surprise to find more efforts to manage standards in the regulatory framework. OfS have called for the sector to define standards beyond thresholds, with a particular focus on degree classification. This aligns with one of the ‘core’ practices under ‘standards’ in the newly proposed quality code, with an intended outcome that: “Students achieve standards beyond the threshold level that are reasonably comparable with those achieved in other UK providers”.
Academic standards – as opposed to threshold standards – are set and maintained by the individual Degree Awarding Bodies (DABs). To start to regulate these at a national level is a real challenge for autonomy. With the Framework for Higher Education Qualifications (FHEQ), credit frameworks, subject benchmark statements, characteristics statements and external examiners all already used to assure standards, this is a significant rejection of existing practice.
Unexpectedly arriving in the consultation questions, having had no mention in the main text, we see the prospect of the OfS looking to alternative methods of assessment, such as Grade Point Average (GPA), to inform their work on sector-recognised standards. Jo Johnson has always been interested in GPA to tackle grade inflation, but when trialled in some providers it saw a patchy application, with huge variation in calibration and implementation. Alas, bringing in a new a GPA classification system to an autonomous sector wasn’t the silver bullet needed. It’s not a new classification system but a standardised system.
Where is quality enhancement?
I’ve already discussed the lack of meaningful enhancement in the newly formed Quality Code consultation on Wonkhe, and the difficulties this presents to Scotland in particular. Yet, the whole concept of improvement with regulation is missing and at points rejected in this consultation. By moving to an almost entirely metric-based system with baseline lead indicators, the OfS will only be interested in those who dip below baseline, rather than those who dip below excellence. Instead, they argue that the competitive market will provide the enhancement incentivisation required to ensure improvement:
“Once meeting a high minimum standard, the OfS will leave autonomous institutions to flourish on their own terms and will instead shape the market by supporting effective demand (in particular, through effective provision of information).”
This market-driven system is so out of sync with the Welsh and Scottish regulatory systems and principled aims, it’s hard to imagine how quality assurance can remain UK-wide. It looks likely that QAA are to be the newly Designated Quality Body, as the only ones to enter, but what they’ll deliver will differ dramatically from the quality assurance they originally developed. As a UK-wide organisation, they’ll have a task ahead of them to keep this increasingly fragmented sector together.
Find the full Wonkhe index of all documents published by DfE here and all of Wonkhe’s coverage of the new framework at #Regulation.