Since providers registered in England that wish to charge higher level tuition fees submitted their required “access and participation” plans last year, we’ve been expecting a summary analysis from the Office for Students.

Providers themselves will have had plenty of analysis already. Of the 171 plans approved by 31 October 2019, 164 have seen mitigations applied, 90 have advanced monitoring requirements, and 79 have received formal communications. As the documentation explains:

These cover a range of issues, and may, for example, require providers to undertake further work, develop new interventions, or reset their targets. This reflects the high expectations we have set for improvement.”


We have asked some providers to look again at the assessments they have made of their most pressing challenges and the ambitions they have set for themselves, and others to make improvements to their evaluation strategies.”

Though mitigations abound there have been no additional conditions of registration applied – you’ll recall, perhaps, the eye-catching decision to put conditions around access on Oxford and Cambridge shortly after registration decisions started to be announced. We can take this as a (heavily qualified) approval of the general direction of institutional planning.

Key findings

The point of today’s publication is to look at the plans in combination – to identify key themes and issues, and to compare targets to the Key Performance Measures (KPMs) that OfS have set on behalf of the sector. The latter causes some interesting problems that we will get to presently – but to briefly summarise the former:

  • Relatively few providers have set ambitions to improve access for mature students – there will be regulatory and funding incentives developed here.
  • There’s a perceived need for collaboration between universities, colleges, and schools – and we should keep an eye out for this in the OfS funding method consultation.
  • There’s been some commitments on gaps across the student lifecycle for smaller or local groups of underrepresented students – care leavers (in 49 plans), estranged students, and Gypsy/Roma/Traveller communities.
  • In terms of target setting – low participation neighbourhoods have been the focus of access work, with disability and ethnicity being the primary focus for work addressing success and progression.

There’s a detailed qualitative analysis of the plans to follow, but this report highlights some excellent practice – it is a shame that most press coverage is likely to focus on the idea of middle-classes being “squeezed out” of Oxbridge.

Seeing the future

This “squeezed out” narrative has come from the idea of providers proactively recruiting from historically under-represented groups to meet targets – OfS heaps praise on:

Ten high-tariff providers committed to reaching at least a ratio of one entrant from the lowest participation areas to every three entrants from the highest participation areas by the end of the plan, in line with the OfS KPM.”

But the targets in the plans can be added together to generate projections of the way all of these KPMs will be addressed (I’ve listed the KPMs in this table as a reminder, the full detail is here):

KPMOfS Key Performance MeasureAnalysisImplications
KPM2Gap in participation at hightariff universities and colleges between the most and least represented groups.If all high-tariff universities and colleges with targets related to the gap between the most and least represented groups meet those targets, the ratio will have moved from a relatively persistent gap of 6.24:1 in 2017-18 to 3.72:1 in 2024-25. In the longer term, by 2038, the ratio will be much closer to 1:1.The OfS KPM is based on 18- to 30- year-olds in the underlying population, rather than 18- to 20-year-olds in the population of students entering hightariff providers, who are the focus of the access and participation plan targets. This means that at the current rate of progress, more interventions to raise mature learners’ participation rates will be needed to achieve equality in these rates by 2038.
KPM3Gap in noncontinuation between most and least represented groups.If all universities and colleges with targets related to the continuation gap between the most and least represented groups meet those targets, this gap would be reduced from 4.6 percentage points in 2016-17 to 2.9 percentage points by 2024-25If this progress is maintained in the longer term, it is likely that providers will close their own continuation gaps. However, there will be a national gap relating to differences in continuation between providers. This gap will not close until the mid-2030s. At the current rate of progress, more interventions will be needed to improve continuation in those providers where it is lowest, to achieve equality in continuation rates across the sector by 2030.
KPM4Gap in degree outcomes (1sts and 2:1s) between white students and black students.If all universities and colleges with targets related to the gap in degree award outcomes between black and white students meet those targets, the gap would reduce from 22.0 percentage points in 2017-18 to 11.2 percentage points in 2024-25.If this progress is maintained in the longer term, it is likely that there will be equality in award rates between the two groups by around 2030. The rate of progress in the OfS KPM seeks initially to eliminate the element of the gap that cannot be associated with factors such as entry requirements, age and subject of study. Most providers did not use this as the basis for setting their targets, though, so there is a different trajectory in the plans.
KPM5Gap in degree outcomes (1sts and 2:1s) between disabled students and nondisabled students.If all universities and colleges with targets related to the gap in degree award outcomes between disabled students and non-disabled students meet those targets, the gap would close from 2.8 percentage points in 2017-18 to 1 percentage point in 2024- 25.This would represent a narrowing of the gap to a level close to equality by 2025.

This represents the approved plans described above, and thus an OfS-agreed level of movement towards the goals expressed in the KPMs. But you’re probably wondering about KPM1 – the gap in participation between most and least represented groups, very much a meta-target.

Well, OfS will not be setting a target for that one until we get a response to the Augar review – now expected alongside the spending review at some unspecified point later this year. Providers have of course set their own targets relating to this KPM, so we wondered if the OfS had an impression as to how the participation of less represented groups would change in the five planned years. A fair question to ask?

Apparently the OfS doesn’t know how much impact these plans will have on a sector-wide access gap between high and low participation groups! This being pretty much the entire point of this exercise we were surprised by this, to say the least.

Yes, but how does it extrapolate?

There’s a great deal of detail about the methodology behind this report – we were startled to note that OfS were reduced to running text analysis software and a manual sift to identify institutional targets in plans, despite recommending the use of a template that (one would hope) was designed to allow easy extraction of such information.

These targets were examined against a version of the 2017-18 student dataset (2016-17 for KPM3), with the OfS KPMs recalculated using the same historic data (from the Access and Participation dataset that underpins the infamous dashboard). This latter offered one big shift – in KPM2 – as the version used in this exercise is only interested in “young students” rather than students aged 18-30 in the published target.

The combined targets were compared against “scenario 2” – what the sector would look like if each institutional gaps (linked to the KPMs) were zero in 2024-25. This scenario didn’t show the sector as completely equitable under such conditions. The remaining gaps (due to the distribution of student groups between providers and across subject areas) were seen as “structural” – the institution specific gaps as (you guessed it) “unexplained”.

In examining the targets against the unexplained gaps, OfS used a number of assumptions. One in particular stands out:

For KPMs 3 to 5, when applying the targets to the historical student data, we assumed that the size of the student population will remain constant. For KPM2, for projection purposes, the size of the population is assumed to grow only by the numerical increase in the POLAR4 quintile 1 entrants.”

This is odd because providers will have offered growth projections on two separate occasions – within this exercise (we don’t get to see that) and as part of wider financial planning. The latter was famously optimistic. We note this because the way in which the sector grows in future is (theoretically) constrained by these access targets – we’d expected to see some mapping of the plans against growth, if nothing else to answer the middle-class squeeze claims. This is as close as we get:

KPM2 – increase of around 6,500 quintile 1 entrants admitted to high-tariff providers in the 2024-25 cohort compared with 2017-18.

KPM3 – projections represent an additional 500 quintile 1 entrants continuing in the 2024-25 cohort compared with 2016-17 levels.

KPM4 – an additional 1,900 black students being awarded a 1st or 2:1 in the 2024-25 cohort compared with 2017-18 levels.

KPM5 – cohorts, these projections represent an additional 750 disabled students being awarded a 1st or 2:1 in the 2024-25 cohort compared with 2017-18 levels.”

Just look at KPM2. Given the percentage targets, I’d be surprised if high-tariff providers admit only an extra 6,500 entrants in 2024-25 compared with eight years earlier – and for every Q2-5 entrant they’d need to up this number. We have the data to do this better – why not use it?

Financial support

One of the traditional ways in which providers have met obligations in this area has been through financial support – either through fee waivers (an early popular tactic but now largely gone) or through bursaries or hardship schemes. We used to be able to look at the total intended spend on student financial support and divide that by what OFFA called an “OFFA countable” student to both compare provider type and the (at least planned) generosity into the pockets of the poorest – but not any more.

The concept of the “OFFA countable” is gone, and of course these days providers have to focus on “what works”, demonstrating the efficacy of their investment – after all:

improved outcomes for students with similar or lower levels of investment, or an evidenced-based increase in spending, should demonstrate better value for money for the taxpayer and students”.

One of the baked in assumptions to the original debate over “higher level” fees and the creation of the old OFFA was that it was so obvious to all concerned that student financial support was the answer, that universities would all commit to topping up the student maintenance system through access spend, and monitoring would show us the detail.

But now we’re more focussed on narrow efficacy and proof, not only is assessing universities’ contribution to the student finance system much harder, but it’s also likely to be worse overall. The document suggests a figure for financial support for the (analysed in this slice of the) sector as hovering around £330m for each of the five years, and also says that “investment in the areas where we continued to collect information has broadly been sustained between the 2019-20 plans and those for 2020-21 to 2024-25”.

Assuming that’s as true for your KPM2 high-tariff providers as it is for everyone else, whichever way you look at it that does awfully sound like less money to go around for more disadvantaged students. Bear that in mind when the usual voices start suggesting that some APP spend right now is “wasted”.

And finally

We’ve written before about OfS’ intention to bring together its disparate (and often contradictory) activities in ways that may terrify some people, and to that end the very final paragraph in the document might scare some:

We are also actively seeking to align our regulation of access and participation more closely with other elements of the regulatory framework such as the TEF and the quality conditions in the regulatory framework, to ensure that these different aspects of our regulation work consistently and coherently with one another. Our consultation on the TEF during 2020 will explore how it can more effectively support access and participation priorities.

Is it possible (for example) to have subject-level TEF without subject-level access and participation regulation? Some might view that as an unacceptable intervention. But the gaps (in particular) in the courses leading to “the professions” might tell another story altogether.

One response to “An OfS analysis of access and participation plans

  1. Michael Barber invented Government delivery standards and targets when he was at No.10 under Tony Blair. I do hope he and his colleagues have learned from the pros and cons of that experience in schools education and since then!

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