Blanks and omissions in HEFCE’s quality plans

Having read HEFCE’s consultation on the future of quality assessment, I have been trying to envisage the quality and academic standards landscape that HEFCE wants to create, and how it would differ from the current landscape.

During the process I have found some expected blank spaces but also some omissions, including in the datum points that HEFCE (or the new body that it might need to become) will need to provide for those who will be required to navigate this new terrain. As a first response to the consultation document, this post focuses on blanks, omissions and perhaps misunderstandings (including mine).

The QAA

What is most obviously missing on this new terrain is the Quality Assurance Agency for Higher Education (QAA). If not the point of this exercise, this may be a key element: to eject QAA from the niche it took over from the Higher Education Quality Council (HEQC) and HEFCE’s own Quality Assessment Division in 1997, to create a vacancy that the ‘lead regulator’ of the system that HEFCE can fill.

The academic infrastructure

What also seems to be missing to a large degree is the product of almost two decades of development in managing the quality of learning experiences for students and safeguarding the academic standards of their awards and credits – what was colloquially referred to as the ‘academic infrastructure’. Starting with HEQC’s Graduate Standards Programme in 1996-7 and continuing under QAA, backed by the authority of the 1997 Dearing Report, frameworks for higher education qualifications were developed for the home countries, as were the subject benchmark statements, practice notes and guidance on the uses of credit-based systems, and the Code of practice.

Together, these documents provided invaluable reference points for managing higher education provision and the standards of the awards to which it leads. QAA was not responsible for these documents: they were accomplished through the dedication of thousands (no exaggeration) of experienced academics and professionals, in a shared endeavour facilitated by QAA.

Subsequently they were transformed by an unknown QAA bureaucrat from ‘points of reference’ to the ‘requirements’ of the UK Quality Code for Higher Education (the Quality Code), the Consultation document envisages ditching the Quality Code, other than as a temporary baseline ‘requirement’ for new higher education providers and delinquent providers. It does, however, favour the retention and development of the Framework for Higher Education Qualifications. It will need to be established whether these provisions will suffice (as HEFCE believes) for its proposals to be ‘compliant’ with Part 1 of the Standards and Guidelines of the European Higher Education Area.

For the future, HEFCE proposes developing a “simpler expression of the baseline requirement [i.e. the Quality Code] for publication”. This is worth pursuing. The consultation document is silent, however, on how this “simpler expression” of the Quality Code is to be produced, and by what or whom.

Likewise it is silent on how the FHEQ is to be developed “to be a core component of future approaches to standards assurance and to be used by all higher education providers across the UK” (as indeed it is now), and how it is to maintained in future. It will be interesting to see whether this “simpler expression” and new FHEQ will be produced by peer groups, working transparently, or by administrative fiat.

The consultation document states that under its proposed arrangements “there would be a significantly reduced requirement for the cyclical review of baseline compliance conducted by an external agency” with “a greater reliance on an institution’s own review and governance processes, on data already submitted or to be submitted to the funding bodies, and on the strengthening of a number of the external elements already in the assurance system”.

These proposals make good sense and they plug what has been a yawning hole in the area of governance in QAA’s audit and review arrangements for universities. How the commitment in the consultation document to reduce cyclical reviews fits with what is evidently the Government’s intention to have a “cyclical, external, independent, peer review [as] part of the coming [Teaching Excellence Framework]” (under paragraph 112), is not clear, however.

Standards

One of the most telling exchanges in recent years about the academic standards of first degrees took place during in 2008 between the members of the Innovation Universities, Science and Skills Committee and the vice chancellors of Oxford Brookes University and the University of Oxford, in which the two vice chancellors were asked about the equivalence of the degree awards they made in the same subjects and declined the challenge.

The consultation document appears to take up the challenge, proposing the “calibration of degree standards” and to take steps to counter public scepticism about grade inflation by providing “better evidence of the reasonable comparability of academic input standards” (paragraph 88). It notes “the progress made by the Australian higher education sector in seeking to provide opportunities for examiners to share and develop their views about academic output standards through calibration activities” (paragraph 88). Something to look forward to there.

For the future, greater clarity on HEFCE’s definition of the term “academic output standards” would be helpful, together with an explanation of how it relates to ‘learning outcomes’, a term that is absent from the consultation document but which runs through the recently approved Part 1 of the European Standards and Guidelines.

It seems that HEFCE is happy to consign 20 years of painstaking peer-based developments in describing and supporting academic standards to the bonfire. It remains to be seen whether higher education in England particularly but also in Wales and Northern Ireland will take to these proposals as well as the imminent prospect of the TEF.