The actual Office for Students (OfS) has responded to the majority of the sector laying off thousands of staff by saying almost nothing about students’ rights, or explaining how to go about “bold” transformation in a way that protects them.

And so, as usual, the OIA steps in in that quiet, subtle way it does by officially publishing a collection of case summaries on student transfers that are really a collection of case summaries on transformation tactics.

One is about a withdrawal of optional modules leading to a student leaving, where the OIA reminds the provider that it is supposed to deliver what it promised. Those clauses that label some changes as minor were never designed for large-scale redundancies.

Another is about a PSRB not accrediting a course leading to a transfer, where the OIA reminds the provider that PSRB accreditation is a key bit of the material information students make a choice on.

One is about a campus closure, where the OIA figures that the student was promised location A and so should be supported with costs to attend at location B. One’s about reasonable adjustments not manifesting, and another’s about a course closure.

The problem for the student in that one was that they could not accept the transfer support package due to having young children, which prevented travel to the new university. They complained, arguing that that left them uncompensated for tuition and maintenance loans from their first and second years – and they requested compensation for lost earnings after leaving paid employment to join the course, as well as additional compensation for distress and inconvenience caused by the impact on their mental health.

The university said no, of course – it argued that the transfer support package was intended to cover additional costs from having to extend studies, not tuition and maintenance loans. It also said no to compensation for loss of earnings, arguing that the decision to leave employment was unrelated to the PSRB’s withdrawal of accreditation. It offered a Cert HE exit award, and as well as £2,000 already paid, offered £7,500 as a gesture of goodwill.

When it got to the OIA, the big concern was that the compensation offer failed to adequately consider the student’s circumstances, particularly as they were unable to complete the course and were left with significant loan debt through no fault of their own. Although the university had offered an exit award, the OIA thought that was insufficient because the award didn’t allow for full credit transfer or access to the professional workforce.

It was also concerned because the uni asked for additional evidence before it would reconsider its financial offer for distress and inconvenience, despite the evident impact of the situation on the student, whose circumstances clearly demonstrated the significant distress caused.

Once the OIA had intervened, the university had another “deal or no deal” think, and this time offered a full tuition fee refund to the SLC, over £28,000 for loss of earnings, and £7,000 for distress and inconvenience. The student accepted the offer.

It all ought to put some guard rails on the way in which restructures are panning out, but I’m again left worrying that without wider support, the old OIA theory of change is under severe strain.

In better times the idea is that caseworkers read the summaries and then providers change their ways. But in tighter times, the instinct of ploughing ahead anyway and hoping that students don’t complain will kick in. Rights are rationed to those with the stomach or resources to fight for them.

We’re still waiting, by the way, for the consultation on a new OfS condition of registration relating to consumer protection, something promised over and over again in different forms since 2017.

That should be along just in time for it to be too late for students to complain about the latest round of course transformations.