Not doing much franchising? I wouldn’t be complacent

I’m not arguing here for collective responsibility (although that’s clearly something to think about) and nor am I suggesting that there’s a bunch of hidden subcontracting going on.

(Notwithstanding that there’s a lot of online degree and TNE work floating around that I suspect doesn’t get the attention it deserves at Senate/Academic Board or Council/Board of Governors).

I’m talking international.

It’s not a huge stretch to imagine that the intro to a brief on risks there could read:

Many universities and colleges in England recruit large numbers of international postgraduate taught students. While this can bring benefits, we consider that business models that rely heavily on international PGTs also represent increased risk.

Unless managed actively and carefully, such arrangements can negatively impact students, the reputation of English higher education and the university or college itself. This Insight brief examines the nature of such arrangements and the risks they carry, and suggests ways these risks may be mitigated by better management and oversight.

I say that partly because the list of examples of risks to student recruitment and support in the brief seems to be very easy to edit across in terms of the allegations that float around:

• Agents have recruited students to unsuitable courses, for example by misrepresenting the qualification that the course delivers, or the requirements needed to complete it successfully.
• Agents have used inappropriate methods to recruit students, for example incorrectly suggesting that the UKVI financial requirement will be enough to live on
• Students have had to pay excessive charges to recruitment agents as part of the application process.
• Students with very weak English language skills have been told these are sufficient to allow them to study on a course, without the university putting in place the support to allow them to succeed.
• Students have paid agents or other third parties to falsify English language tests, to allow them to enter courses without attaining the required standard of English.
• Providers have lowered entry requirements for the sake of meeting recruitment targets, often resulting in lower entry requirements for international students than for those for home domiciled students.
• A lack of transparency for students in general about the relationship between the agent(s) and the provider.

On outcomes, in OfS theory there’s a good story to tell – for full-time Master’s students, the 4-year aggregate continuation rate is 95.5 per cent versus 89.4 per cent, with an inevitably similar differential on completion. OfS doesn’t use whatever HESA/Jisc supply via the Graduate Outcomes survey in its dashes on progression.

The problem is that once you think about progression and completion in the context of international PGTs for more than 5 seconds, you’re thinking about how hard it would be to drop out of a 1 year Master’s course for an international student, along with the pressure from UKVI to get students to completion.

If nothing else it shows up what a faulty set of stats the three core measures are as a proxy for quality in general (it’s not as if the student finance system doesn’t trap home UGs or as if there’s no pressure on drop out there) but especially for international PGTs.

The next list of crimes – examples of risks to course quality that are more “B2” than “B3” in the franchising brief seems relevant too. Again, I’ve not had to change many words:

• Students have not been clear about what constitutes academic misconduct, or the line between seeking appropriate student support and academic misconduct.
• Students have submitted assessments that are not their own work, in some cases with the complicit support of staff members.
• Staff managing international recruitment have been incentivised to prioritise recruitment and retention of students above rigorously reviewing course quality and internal quality assurance.
• Providers have retained a significant proportion of the tuition fees for courses taught to international students, without evidence that students have been told this is happening or
• What the cross-subsidy is being used for. This raises questions about the funds available to teach and support the international students on their courses. Some providers profit substantially from international students.

The third list – examples of risks to providers – was also devilishly easy to edit:

• Providers have uncovered pockets of widespread academic misconduct.
• Inadequate contracts have made it difficult for providers to terminate agreements with their recruitment agents when concerns have arisen about the accuracy of information supplied to students.
• External auditors have raised significant concerns about the oversight of recruitment
• Providers have prioritised the financial benefits of these arrangements over the quality of courses – for example by reducing the entry requirements for students, and so putting pressure on staff to support students to remain on unsuitable courses, and resulting in poor student outcomes and potential regulatory action.

I’d add others. There’s still no NSS for international PGTs. One of the other release valves in the system is student complaints – but the willingness for an international student to raise one is significantly diminished if the body it complains to appears to be an arm of the state for the purposes of immigration, and when those complaints would likely take longer to resolve than their visa is stamped for.

What does come in is a substantial volume of academic appeals – but the content of those appeals that relates to things they can complain about rather than the grade they got tends to be systemically dismissed as “well they would say that”, usually put more politely as “you should have complained at the time”.

Providers that have a proper commitment to learning from complaints should really convert every doomed academic appeal into a complaint about service provision/support – in England any imminent review of OfS Condition C2 should really mandate it, along with learning from both successful and failed academic appeals.

But broadly, if the risks were easy to copy across, the governance-level steps should be too. And they are:

• Undertaking robust, expert and independent due diligence before expanding international PGT and entering into partnerships with sales agents
• Agreeing clear and documented strategic objectives for these activities
• Undertaking a clear and documented assessment of the risks these activities present, and the mitigations the provider is putting in place to reduce them
• Developing and acting on a clear and effective plan to review the value and operation of international PGT regularly, and if necessary, ending it
• Developing a clear and effective plan to protect students’ interests, including enabling complaints
• Reviewing the composition of the board, and taking steps to ensure it reflects the skills needed for this type of business model
• Clear induction and training for all members of the governing body to ensure they are aware of their roles and responsibilities
• Robust succession planning, to ensure that terms of office for key senior staff and members of the governing body are managed in line with relevant codes of governance
• Considering whether remuneration of the chair, or members of the governing body, is appropriate to encourage people with the necessary skills to apply
• Reviewing academic and related governance arrangements, to ensure that the governing body receives the right kind of information in sufficient detail

The problem? I have even less faith that the regulation in this area will ever be up to scratch (the “level playing field” now allows vast patches of said field to go uninspected) and the existing financial incentives are even greater.