Student input into APPs must not disappear into a regulatory vortex

Francesco Masala is President at The SU, University of Bath

At the moment, universities in England are required to submit a return on their Access and Participation Plan progress and are required to publish an impact report, which is effectively a self-review.

This allows access and participation work to continue with little accountability, and allows universities to create impact reports that over-highlight successes (however slim) and diminish issues (however significant). It’s important that universities are accountable on their progress on access and participation.

So this year, alongside the Access and Participation Plan (APP) return required by the Office for Students (OfS) from universities, the regulator allowed for an optional, independent submission from students and SUs to help with that accountability.

The idea was to allow some student input to scrutinise the progress (or the lack thereof) of their institutions on access and participation. OfS was keen to encourage students and SUs to take part, and even created a suite of guidance documents to help them develop their submission.

The timings were inevitably unfortunate – as the submission (as well as the university return) relates to the 2019/20 academic year. Given that this has been the first year this has been invited, this may have created significant difficulties for students and students’ unions alike.

This first-time submission was also created when students, officers and staff members were still busy weathering the ongoing impact of Covid. This may well have reduced the depth, and the potential, of the submission.

Reflecting on our own process here and from talking to SUs around the country, there are some learnings from this year’s submission that should really help students and SUs in filing impactful submissions in the future.

1. Institutions need to be fully cooperative with the representatives in charge of filing the submission

At Bath, we have been extremely lucky in that the Widening Participation team solicited our engagement with the submission and was extremely forthcoming with information whenever required. It engaged with us at multiple stages of the research and creation of the submission.

However, it is clear that other institutions’ approaches were way less welcoming of an independent, student-led review. Needless to say, it looks the extent to which an institution was willing to provide information and data to the submission leads directly impacted the extent to which the student submission could be impactful.

As well as poring over the submissions it did get, the regulator should pay close attention to those universities that have not had a student submission this year – and even closer attention to the representatives who have complained about the lack of cooperation from university staff to create the submission.

Non-submission may signal a wider problem with support for student engagement in the university, and for future submissions, the OfS should strongly encourage (if not mandate) institutions to fully cooperate with students in the creation of the submission.

2. Institutions need to accessibly communicate their access and participation aims to their communities

As SU President, I sit on the University of Bath’s APP Monitoring Group, which meets regularly and reviews progress towards our access and participation targets. Yet, until I dedicated entire working days to create the submission, I did not understand much around the work on access and participation, particularly relating to the on-course elements of the student lifecycle.

As a student officer at the heart of university decision-making, if my knowledge was rather underdeveloped, I cannot imagine what it must be like for students. Fundamentally, I believe that these student submissions have the potential to be really impactful on the monitoring of access and participation within an institution. But to maximise this impact, universities and SUs need to start working over the summer to improve the communications of these targets and activities to students.

On the representative side, officers need to be brought up to speed transparently by their universities on the APP, areas of progress, and areas of concern, from the get-go. From looking at feedback from officers at other institutions, it was clear that most found the process difficult to navigate. This is because APPs are not easy documents to analyse and understand.

A relatively large sum of money is spent on access and participation activities across universities, and APP funding is given to a large number of projects across different departments. If other universities are anything like Bath, effective impact reporting of these activities is patchy and findings are not widely shared. Institutional coordination and communication on what is being done on access and participation would be crucial to enable stronger student submissions in the future, as well as providing transparency on an area of university operations that is still obscure to many.

In many ways it really is this simple. If neither students nor their representatives understand APPs, that would suggest that the work is being done to students rather than with them – the very opposite of the co-production ideals we ought to aspire to.

3. OfS guidance and support should develop in the future

As a member of the OfS Student Panel, I had sight of and commented on the guidance documents the regulator published to support students in creating the submission. After the first year of submissions, however, there will definitely be areas of improvement on the guidance to support students further.

I hope OfS will carefully analyse the open feedback on the submission process which was asked to all lead representatives at the point of submission, highlighting and correcting issues ahead of the next academic year. This work should ideally be done during the summer, ahead of the 2021/22 academic year.

The revised guidance, alongside the information on how to hold focus groups, interviews, etc., should also include new guidance on how to effectively monitor student engagement with APP and collect effective data on this throughout the year. This will be incredibly supportive for the students and lead representatives at the point of submission, as impactful qualitative and quantitative data will already exist. SUs should also play an integral role in this.

Furthermore, we will now have a pool of student representatives who will have already engaged and filed a student submission once. The student panel, who has directly shaped the documentation guidance, is well placed to gather support from representatives to hold a webinar, or multiple webinars, on the student submission. SU officers and staff would be able to get direct expertise and tips on the submission, which would help submissions becoming more impactful in years to come.

4. The publication of the submission, whatever its format, should be encouraged and supported by OfS

Right now, sadly it is unclear what happens to the student submissions once they get filed in. At the moment, it feels like they have been thrown into a huge void.

The regulator needs to seize the impetus created by these submissions – this has been a crucial way with which students have been able to give their authentic voice to the OfS about the work of their university. If we want the student submission to continue in the future (and, by all means, we should) this feedback loop needs to be closed somehow.

Students who spent time and energy in preparing these reports in a very obscure area of an institution’s operation are likely to be disillusioned and disheartened if the cycle of the report ends with it being submitted to the OfS. I hope that the regulator will follow up with the students who have filled in a submission, and give any concerns raised the attention they deserve.

It also appears from the OfS website that the publication of the student report hinges on the university being willing to do so. This is ridiculous, and directly impacts the independence of the submission, which is stated on the OfS’ webpage. Students’ unions are accountable to their members and we should kill stone dead any idea that this kind of feedback should be submitted under a Chatham House rule!

The regulator should encourage students (ideally through their SUs) to publish these submissions regardless, and facilitate a resource bank through which students in future years can be supported in creating a submission.

I strongly believe the student submission has the potential to become an important, accessible, and student-led part of monitoring of university activities on access and participation. It also provides a voice to students directly to the Office for Students, in a time where the regulator needs authentic student engagement more than ever.

If SUs seize the moment, if universities are willing to cooperate, and if the regulator facilitates the growth of this endeavour (none of these are small feats), the submission could become a regular and exciting part of effective representation in higher education institutions.

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