It’s almost a throwaway line in the Labour manifesto: “We will act to improve access to universities and raise teaching standards.”
Possibly it was wedged in to neutralise any potential random accusation of not caring sufficiently about higher education quality from a Conservative Party that has chosen to nail its colours to the mast of “cracking down on low quality courses.” More likely there’s a sense in Westminster that you can’t talk about higher education policy without acknowledging the things voters care about if they stop to think about it: access and quality.
The current access and participation regime in England in which higher education providers are essentially required to demonstrate that they have a strategic grip on which students are at elevated risk of poor outcomes and explain, with evidence, what they plan to do about it, has the hallmarks of a maturing system and at a high level seems to have the buy-in of the sector. However, it is very tightly focused, in line with OfS’ legal duties, on individual providers. A Labour government could usefully supplement the current regime by putting its energy into looking at the potential for, for example, achieving efficiencies in regional collaboration around access, enhancing pipelines between level three providers and universities, and supporting things like foundation year provision.
By contrast, the quality regime, focused on investigating those providers whose student outcomes fall below a pre-defined threshold as well as broad subject areas or forms of provision the regulator has reason to be concerned about, is only just getting started – and the sector remains to be convinced of the merits of this approach.
Outcomes
There are a number of questions that remain open for debate. One is whether the student outcomes-based approach is an appropriate way to assess quality. The thinking behind the adoption of student outcomes was to focus attention and resources at institutional and national level on the areas where there are genuine risks to quality. That’s actually on paper a pretty smart proposition, especially if you acknowledge that the outcome measures you are using are more of a potential warning sign rather than absolute quality measures. Also, given that higher education institutions are responsible for their own academic quality there’s in theory no reason to go poking about unless there’s a concern raised.
But that proposition didn’t anticipate things like a global pandemic that would see teaching and learning transformed overnight, nor a serious cost of living crisis that would pull students away from engaging with learning and teaching and on-campus activity, threatening outcomes in ways that institutions genuinely struggle to address, especially given their own funding challenges.
Something that should probably have been anticipated, but apparently wasn’t, was that there is a capability difference between mature, well-resourced multi-faculty providers and new, developing, or small providers in terms of assuring quality – and that franchise contracts create a degree of murkiness that make it hard to judge how that’s playing out in practice.
The solution to challenges like these isn’t necessarily “more inspection” – but there are serious questions about the legitimacy of an approach that is not geared up to engage with input and process aspects of quality in a rapidly changing learning and teaching environment, with a significant spread of institution type and mission.
Another question is what the quality regime actually causes to happen on the ground. It’s a solid regulatory principle that you don’t intervene if there’s no reason to think there’s a problem. But the higher education sector has grown accustomed to a quality architecture that has historically done much more than simply periodically assess quality.
The QAA is no longer the designated quality body for English higher education. But it has in the past – and continues to for those that want to stay involved – had a developmental and convening role, issuing guidance and advice, identifying areas of shared concern, and generally keeping an active conversation going about academic quality and what it should look like. This, plus the expectation of a regular review, ensured that the practice of maintaining academic quality was established and taken seriously in institutions, and created a community of practice across the sector. The recent launch of a new sector-owned Quality Council independent of regulatory expectations suggests that the sector sees the merit and value of this kind of joint activity.
You might argue that all of that activity is just so much busy work, or worse, an example of an over-mighty phalanx of higher education quality managers creating the conditions for their own survival and proliferation. But the counter argument is that all that activity is, in both perception and reality, part of what gives the UK sector licence to call itself “world-leading.”
Tertiary quality
A third dimension, not considered at the point of design of the current regime in England but very much live in Wales and Scotland, is the merits of a tertiary approach that creates the space for a single quality regime for further and higher education. The new Quality Code from QAA is explicitly designed, as QAA chief executive Vicki Stott has said elsewhere on Wonkhe, “to offer practical help to a wide range of post-secondary education providers.” While the Code is still focused on higher education, it aims to capture quality principles that apply beyond higher education providers to other “tertiary” providers.
The prize for those providers is potentially the opportunity to move on from inspection-based regimes like Ofsted to having a greater degree of autonomy and responsibility for their own quality. The risk is that doing that proves to be quite expensive. FE colleges, in particular, are already subject to multiple competing quality regimes across their different kinds of provision. A tertiary framework such as those under development in Wales and Scotland could help to relieve some of that pressure and support further efficiencies and coherence in the post-16 system, but there would be a culture shift involved.
Labour’s manifesto promises a post-16 education strategy, which would set out to “better integrate further and higher education and ensure high-quality teaching,” including setting out the roles for different institutions, and student pathways between institutions, as well as “strengthening regulation.” The spirit of this commitment is derived from the Labour party’s 2022 review of skills spearheaded by former Labour education and employment secretary David Blunkett which argues:
Post-16 learning, both vocational and academic, must be seen as a seamless pathway through apprenticeship, further and higher education – which instead of being juxtaposed as competitors, should instead be seen as partners in delivering a high-skill, high-productivity, technologically enabled workforce of the future.
The deeper thinking on this remains to be done and there’s a sliding scale of integration that wouldn’t necessarily have to include quality but probably would, given the reference to high-quality teaching. But it really makes sense to ask the quality question in the context of the larger issues of institutional structure and missions, range of qualifications and pathways on offer, funding, and regulatory oversight.
The Association of Colleges (AoC) has published its own case for adopting a formally tertiary approach in England, built around a national post-16 education and skills strategy but with a local flavour in provision depending on the particular needs of devolved regions – and which would also see a greater degree of collaboration and coordination across the various post-16 providers. Intriguingly, AoC recommends that the post-16 system should be steered by a “national social partnership body” which could work across government agendas on health, green jobs, etc, and set national priorities for education and skills provision.
There’s also an open debate on whether Labour might implement a full-scale review of tertiary education in the next Parliament with a view to regulatory and funding reform, or seek to make modest tweaks to the system via existing mechanisms. Whichever approach is considered it would be wise to look to Scotland, whose “enhancement-led approach” to quality in higher education have caused many a pro vice chancellor to gaze wistfully over the border, and who have gone the furthest of all the UK nations in thinking through what a “tertiary” quality regime might look like.
It’s better over the border
Earlier this year I spoke with a number of senior leaders of Scottish universities, exploring both their experiences of the enhancement-led approach, and their views on the development of the tertiary quality agenda, to see what the rest of the UK could learn. In 2022 Scotland celebrated 20 years of the enhancement-led approach to quality, including with this Wonkhe article from QAA’s Ailsa Crum. As Ailsa relates, at the early stage of the adoption of the approach it was contested – especially as to whether it was possible to conflate quality assessment and enhancement. But the system has evolved and matured, crucially, with the active engagement of Scotland’s institutions via the Scottish Higher Education Enhancement Committee (SHEEC).
A key feature of the enhancement-led approach is a cyclical review of institutions, focused on how institutions are using quality processes to improve learning, teaching, and student support, incorporating an evidenced institutional reflective self-assessment. Notably, this is not a data or metric-free exercise; student experience and outcome data are widely used in Scotland as elsewhere (arguably Scotland’s colleges and universities are far more subject to metrics-based expectations than England’s via the Outcome Agreements with the Scottish Funding Council). But vice principals report a greater degree of trust in institutions to take interpretive ownership of their own metrics and a greater regulatory orientation towards the credibility of future plans rather than focusing on litigating the current state of affairs.
Even in my first two weeks in Scotland I realised enhancement is the word – every part of quality is about how we enhance the quality of learning and teaching for students. Quality is not a stick to beat institutions with.
Rachel Dickson, Deputy Director Academic, The Glasgow School of ArtOne of the commendations in our latest review had been a recommendation in a previous review. That goes to the heart of the enhancement led approach: what once was an area for improvement is now sector best practice.
Leigh Sparks, Deputy Principal, University of Stirling
In addition to a regular enhancement-focused review of institutions the Scottish sector collectively agrees and adopts “enhancement themes” which convene activity and small amounts of funding around a shared challenge or area for development, enabling the exchange of ideas, critical investigation of practice, and the creation of shared resources. Student engagement is woven throughout the quality system, via students’ associations and NUS, with a national body, Student Participation in Quality Scotland (sparqs) acting as a convening organisation for the development of good practice and expertise in student engagement.
Collaborative project funding opportunities are helpful and support both innovation and partnership working; the sum of money is fairly modest but direct funding helps ensure that there is a reporting process, enhanced accountability and recognition. Such initiatives also have other spin off benefits e.g. generate new partnerships and provide value added that wouldn’t occur otherwise and there’s also the positive benefit in that the whole is often better than the sum of the parts. So, they act as an enhancement catalyst.
Alastair Robertson, director of the Graduate School at Glasgow Caledonian and chair of SHEEC for 2023-24.There’s a coherence to what’s going on – a process that surfaces useful changes and gives government evidence of positive sector activity and helps unite the sector.
Luke Millard, Dean and Professor of Student Development, Abertay University
A recent evaluation of the enhancement themes by Liz Austen and Stella Jones-Devitt has generated a suite of recommendations for policymakers focusing on the alignment of enhancement activity with national strategic objectives, and a focus on evidenced impact rather than volume of activity. As in England, the embedding of systematic approaches to design and evaluation of change agendas remains a work in progress, but there is lots to see in how enhancement themes have shaped the Scottish sector and enabled a great deal of collaboration and sharing of practice to occur.
Ask anyone in Scotland why all this collaboration and sharing happens and they will tell you it is about the size of the Scottish sector in which you can famously get every institution around the table. The diversity of institution type in England is also cited as a reason why a similar approach would not be as effective. And even the most ardent champions for the Scottish system will caveat that it’s not all cosy consensus and critical friendship. But even if we accept that transplanting the Scottish system wholesale would not be the best option for England there are some things that should be carefully considered.
One is about the relationship between regulator and regulated: there is a degree of trust in the Scottish system that is grounded in a “no surprises” ethos on both sides, that allows for things to go wrong as long as there is a plan to fix it, and that takes a real degree of effort and relationship management to sustain. In England the risk-based approach seems to imply that an institution is either left to its own devices or comes under intensive scrutiny; there is no middle ground in which an institution can sense-check, ask for input, or flag a prospective issue before it turns into something problematic. Scale is definitely an issue here, but so is tone and approach.
A second is about the explicit valuing of facilitating collaboration and a recognition of the impact of sharing practice. There are vehicles to do this in England for those that are so inclined, but the systematisation of collaboration in Scotland around shared agendas gives it a status and strategic importance that is missing in England and reduces the impact it could have.
The third is about the extent to which the quality system makes provision for innovation, both in reducing the perceived risk of trying something and it not going as well as was expected, because the focus is on learning and moving forward rather than on punitive intervention, and in active efforts to create the conditions to stimulate innovation through shared missions, funding pots and a community of practice. Sceptics will say that the system in England is friendlier to innovation because institutions are not bound by scrutiny of processes and are free to do what they want. While this is technically true without the pull factors created through a national framework the cost of innovation is increased, along with the risks, for individual institutions.
The fourth is about the alignment of higher education quality and national strategic agendas that create a sense of active partnership between higher education and national organisations and even government. This is not about the government or the funding council imposing an agenda, nor does it limit the possibilities for institutions to do their own thing. But it creates a virtuous circle in which the government can be satisfied that institutions have a grip on whatever the challenge of the moment is, and institutions can interpret that challenge for their context but with insight and challenge from peers.
Obviously there are tensions in this approach at times; just as obviously it’s far superior to leaving institutions to sink or swim on the basis of protecting autonomy and then criticising them in the media for not doing enough on whatever issue you have just decided is vitally important. Whatever the failures of the current Scottish government on higher education policy, you just don’t see the same critique of quality that England’s universities have had to put up with. The version of a mature relationship between higher education and government that Scotland offers might not suit English providers but maturity and partnership in the national interest should absolutely be the goal.
The shift to tertiary
Scotland’s Tertiary Quality Project is essentially thinking through how the key building blocks of institutional cyclical review and sector-wide enhancement themes can be applied across Scotland’s universities and colleges, with implementation planned from 2024-25. The aim is to create a “more coherent and streamlined tertiary education system” – this is in the context of a system that already has a single tertiary regulator and widespread articulation between colleges and universities.
The appeal for colleges of a tertiary approach is the prospect of taking on greater autonomy and responsibility – and while there’s no reason to think that colleges as organisations aren’t entirely capable of doing that, there is an appreciation that universities have had more practice at it:
After 20 years the enhancement-led approach is embedded in individual higher education institutions’ policy, practice and culture and across institutions working as a collective. With the move towards a tertiary approach to quality assurance and enhancement, universities are keen that these advances and benefits are not lost. On the colleges side, my sense is that colleges are very positive about the move to an approach more akin to that of the university sector but they recognise that they are in a different place, and there needs to be capacity building around an enhancement-led quality culture. And the new tertiary framework needs to be implemented within what is, for both sectors, very challenging financial circumstances.
Alastair Robertson
The extent to which higher education institutions see opportunities in the tertiary quality project is inevitably shaped by their mission:
The tertiary quality enhancement framework is especially exciting for Abertay. We’re a social justice and inclusion university – we mainly recruit locally with students who want to stay in the region. Talking with colleges in the same room and asking what quality enhancement looks like across colleges and universities, how you blur the boundaries between the two has been really useful – there has to be some thinking around access, educational gain and how we track student success through college, how they are progressing into university and out into employment.
Luke Millard
In Scotland as in England, the tertiary approach offers to consider the broad context for access and participation, the ways that different kinds of qualification strike a balance between offering materially different experiences to different students, but also are sufficiently aligned to create meaningful pathways between different institutions and move away from the notion that the type of course you do or institution you attend is a feature of your social background rather than your interests or future aspirations.
But the background to this debate is very much, even more so than in England, a funding challenge which shapes all institutions’ capacity to sustain a cycle of continuous improvement:
A key worry about a tertiary wide quality approach was that it would compromise a framework that both works well and that universities are happy with, and importantly, that is internationally recognised. But the Scottish Funding Council and QAA have done a lot of work on consulting across the university and college sectors, and generally there’s a sense that it’s landed in a good place. So it’s not the review of the quality framework that keeps me awake at night, but how you continue to deliver an excellent student experience on diminishing resources.
Richard Butt, Deputy Principal, Queen Margaret University
The funding question would loom large in any discussion of tertiary in England – the college sector entirely correctly points out that it has seen no cash windfall such as that enjoyed by universities with the £9k fee regime in the last fourteen years and in fact have seen significant cuts to areas like adult learning.
Universities have over decades built up a version of the student experience that is designed around the concept of full-time study, participation in extra-curricular opportunities, exposure to academics who are active researchers in their field, and gold-plated student services. That model is increasingly looking fragile, given the funding pressures on universities and students alike, but universities may well argue that anything that opens the door to “levelling down” would risk harming the UK sector’s international reputation (something, incidentally, that means quite a lot more for the HE sector than for FE, as things stand).
Drawing on a tradition of collaboration, the basically solid relationships with regulators, a pre-existing alignment between universities and colleges, and an HE quality regime that already commands the support of the sector has meant that the shift to a tertiary approach to quality has been less of a bumpy ride in Scotland than it would likely be for England. That doesn’t mean there haven’t been tensions. As with any major policy change agenda, the value of the new approach, to be rolled out from the autumn, will take some years to materialise, where its challenges will almost certainly show up from the outset.
While a Labour government might look to make some quick wins with post-16 reform, there will also need to be some meaningful efforts to build trust and confidence that will create the space to explore what a tertiary quality (and everything else) regime could look like for the English context – it might take a bit longer but ultimately it could deliver a better outcome.
