Seeking validation: OfS and collaborative provision

Among the documents released by the Department for Education alongside its voluminous consultation on the regulatory framework was a research report on validation and franchise arrangements in the English HE sector.

The “small-scale exploratory study”, by ASK Research, produced “suggestions for improvement” based on interviews with FE colleges, alternative providers and degree-awarding bodies. The report’s recommendations focus on structures that OfS can put in place, like an arbitration scheme and a matchmaking service that will bring together awarders and alternative providers. Imagine OfS as the sector’s Tinder and Relate.

OfS should also promote transparency on the costs of validation, the report recommends, and “a central body [should] carry out quality checks and due diligence on all HE providers, especially those looking to enter the sector.” The latter point may raise some alarm bells at HEFCE or QAA which might reasonably have hoped that interviewees were already aware of the quality systems in place.

The basics

If you don’t have your own degree-awarding powers, you need to enter into a validation or franchise arrangement with an organisation that does. This seems pretty straightforward as there should be some threshold for the awarding of degrees to students, not just letting everyone with a printer and a supply of Basildon Bond to churn them out. But there have been complaints – notably from AC Grayling’s New College of the Humanities – that the way validation works at the moment is essentially a closed shop which stifles competition.

If you thought this was small fry in the scheme of things, it’s important to note that validation is big business with the vast majority of the 171 SCITTs (School Centred Initial Teacher Training providers), 219 FE colleges and 244 Alternative Providers delivering their awards in collaborative arrangements.

Validation regulation

The White Paper said: “We will encourage providers to improve validation arrangements, and take a power enabling the OfS to designate a validation service if validation services remain restrictive.” And this will come to pass. Paragraph 394 (and, in a proofing error, also para 396) of the regulatory framework consultation states that:

“…the OfS will take concrete steps to improve validation services, and address some of the barriers providers can face when seeking a validating partner. The OfS will aim to address the lack of transparency and opportunity for providers to compare various offers. This could include actively encouraging incumbents to develop validation services, and setting out exemplar validation arrangements to help informed negotiation between validators and providers who seek validation.”

There’s also the curious arrangement that “the OfS will act as the degree awarding body [where] it will be responsible for the academic standards of any awards granted in its name, and for the quality of the learning programme.” This particular provision – which seems unlikely ever to be put in place, not least because that would mean OfS competing in a marketplace with organisations it regulates (I’m no lawyer, but this screams conflict of interest to me) – is one of the more bizarre hangovers from the Act, something that should probably have been resolved in favour of a sector-derived solution.

You’ll be pleased to hear that OfS won’t be setting up its own alumni association for any degrees it validates as “we would expect students and alumni to primarily talk about having studied at a particular institution… not having secured an award from the OfS.” Though, as the awarding body, degree certificates will show that the validation came from OfS. We have yet to see samples of the academic dress, just one of the many questions still outstanding. In similar trivia, the status of Lambeth Degrees also remains unaddressed in the new framework…

So what?

The extent to which deficiencies in current systems for validation are really a problem is disputed. But whether the problem is significant, or just raised often and loudly by a few interested parties, the direction of travel has been clear in this area. New systems for stimulating and regulating validation will be put in place by OfS. Will the regulator use its degree-awarding powers? Probably not, but the threat of competition from the regulator might be enough to stimulate otherwise more reluctant parties into stepping up.

Find the full Wonkhe index of all documents published by DfE here and all of Wonkhe’s coverage of the new framework at #Regulation.