A few weeks ago I previewed HEFCE’s proposals for a reformed quality regime in English, Welsh and Northern Irish HE and discussed its implications. Today, HEFCE publishes its public consultation and the proposals remain largely unchanged but the debate is as muddled, risky and uncertain as it has ever been.
To recap, the HEFCE proposals envisage:
- A new regime without institutional review
- More responsibility for university governors for their own quality
- An improved external examiner system
- Greater use of metrics to drive improvement
You can read the consultation document in full here and it is well worth doing so. In the mean time, there are big unanswered questions, raised by developments of the Teaching Excellence Framework policy and unease in some parts of the sector about proposals now on the table. Elsewhere on Wonkhe today, Derfel Owen assesses the different proposals and draws some early conclusions about the implications and David Cairns looks at what’s missing.
The Teaching Excellence Framework
On Friday last week, Universities & Science Minister Jo Johnson was expected to give a speech in which his promised Teaching Excellence Framework (TEF) would be unveiled. The speech was cancelled at the last minute and might still take place soon. But in the mean-time, HEFCE have been forced to acknowledge the TEF in their consultation in spectacular fashion.
Despite HEFCE’s intention to do away with institutional review, in a revealing paragraph they acknowledge that the TEF itself could carry with it some form of very familiar-sounding external reviews. To my knowledge this is the biggest hint yet in the public domain about what the TEF might have in store:
we have been mindful of the need to ensure that the overall quality system does not introduce duplication, or increase unnecessary bureaucratic burden on providers. In this respect, it should be noted that initial views from the Government are that a cyclical, external, independent, peer review will form a key part of the coming TEF. (p.33)
The danger now is that there are two competing quality narratives emerging – one being led by the government and the other by HEFCE. And all this poses much bigger questions than simply how HEFCE can avoid ‘duplication’.
It would be bizarre and counterproductive if HEFCE’s commissioned external quality assessment was abolished only to ultimately exist somewhere else in a slightly different, and potentially more onerous form, with less oversight from the sector. And only in England as well, which is as far as the TEF can reach.
And then by a drastic failure of policy, and without a serious challenge by the sector, the regulatory landscape will be even more complicated, potentially more expensive, probably more onerous, certainly more fractured across the UK, and definitely carry less oversight or ownership by universities than under the old regime.
This shouldn’t be allowed to continue and all parties should surely agree at the earliest opportunity how they can go further than merely intend to ‘avoid duplication’, and actually design the joined-up and fit for purpose quality and excellence regime that universities, students and the public deserve.
All this talk of ending institutional review and introducing a TEF ignores some of the regulatory challenges that have emerged with new providers entering the system – most of which can not be compelled by HEFCE to do anything, let alone comply with their mooted quasi-external, metrics-based health check. Meanwhile the government is busy working on their Teaching Excellence Framework which in a world without institutional review, doesn’t seem likely to provide an answer to how quality and standards or the student and public interest will be met across all of the different parts of the sector.
It seems that we’re heading in to very dangerous territory where no arm of the government or the sector can answer how quality or standards will be monitored at alternative providers – only that work is ongoing in designing a ‘gateway’ for which new providers will be able to enter the system through. HEFCE tell me that this isn’t their business – and they are right. But the government, by allowing HEFCE to press head with their plans, and by simultaneously staying silent on the wider regulatory challenges at play, risk sending the signal that far from having a ‘proportional’ system, it will be open season on the student loan book and a whole swathe of the sector and their rapidly growing population of students will fall out of any sort of external checks on quality – let alone excellence.
This could all be fixed by some relatively straight-forward legislation – the heavy-lifting for which has already been done in preparation of an HE Bill that never came. At the very least it should allow HEFCE to bring alternative providers in to their new quality regime and at a bare minimum deliver it proportionally to the associated risks – if not design and implement a fresh inspectorate mechanism for this part of the sector – and whoever else is deemed to pose the greatest risk.
But no one has an answer to how any of this could work, and the government so far has not signalled an intention to provide much-needed legislation. The cost of doing nothing is unimaginably high and I have spoken to leaders from providers of all stripes, concerned that the proposals and their lack of underpinning regulatory clout may not be enough. And it’s clear that there’s as much reason for alternative providers to be alarmed at the direction of travel, as anyone else.
In my last piece on the issue, I warned sector representative bodies that they could come to regret losing their ‘ownership’ role of the quality regime and agency, because it is a key route by which they influence the system. It was interesting therefore to note that following their board meeting on Friday, UUK announced a new working group to “play an active role in ensuring a positive transition to a reformed quality assurance system”.
With HEFCE and the government seemingly heading off in to different directions – neither of which are likely to include levels of sector ownership that universities are used to, particularly whilst such important policy is still in such a jumble, could this be an early sign that the sector is attempting to get a grip on all of this?
Other sector bodies who have responded so far have been fairly muted, with public powder being kept very firmly dry as we enter a protracted period of negotiation and policy development from every conceivable angle and in every possible quarter.
The consultation period for HEFCE’s proposals run until mid-September, and a TEF consultation is now expected in the Autumn. With so much now up in the air, strap in for an intense period for higher education policy.