Let me take you back to July.
After another long year of supporting students through the continued disruption of Covid lockdowns and ahead of the inevitably busy results day and clearing period, colleagues were enjoying a moment of respite.
As the heatwave took hold, it was time to take a moment, clear the inboxes, and prepare for the year ahead.
Following submissions to the Office for Students’ supplementary consultation only a month before, surely this was a moment in which the focus could finally return to planned activities.
Not so fast
Enter: The NSS consultation.
On 28 July, the OfS launched its sixth consultation of 2022 (eighth if you include the consultations on OfS strategy and Data Futures). The UK’s funders and regulators were now seeking views on proposals for updating the National Student Survey. On its own, this is no bad thing.
As reported by the OfS’s phase 1 review published in 2021, the NSS is an important tool for collecting the views of students. It is the only census style survey of final year undergraduates that covers the entirety of the UK. Universities value the contribution it makes to their work to improve and enhance teaching, learning and student experience.
But we all know that to remain useful and relevant, surveys need to be reviewed and updated and the NSS was never perfect. Changes were needed and talking to the principal users of the NSS was the right thing to do.
A shorter consultation
Blissfully, this consultation was a mere 49 pages, rather than the 800 page monsters we have become used to. But, with a deadline of 1 September, the sector had only a month to respond. However, it was not just any old month. With the consultation relating to a student survey and the month in question being August, the timing raised more than one eyebrow.
Still the sector rallied – and over 250 responses were submitted. People, organisations, and universities wanted to share their views. However, fast forward to today’s response and you are hard pressed to find a single area in which the views of the sector have had any impact on the OfS’s intentions.
One of the most startling examples is where the regulator says, about the summative question on student satisfaction, that
[…] around a tenth of comments supported the proposal to remove the question in England.
This clever use of wording attempts to avoid saying what even the most basic maths can tell you, that 90 per cent of respondents disagreed with the proposal.
The OfS’s response? The proposed change will go ahead and the question will be removed from the NSS.
Only around half of respondents agreed with the suggested inclusion of a question on mental wellbeing – but yet again, the proposed change will go ahead and the question will be added to the NSS.
This is not the first time we’ve seen this kind of reaction. On the TEF, despite two-thirds of respondents disagreeing with maintaining gold/silver/bronze ratings and three-quarters of respondents disagreeing with the introduction of ‘requires improvement’ as a fourth rating category, the OfS felt there was no need to amend these proposals.
Regulators and regulated sectors will not always agree. There may be legitimate reasons why the feedback received during a consultation cannot be fully acted on. However, if the view is that it cannot be acted on at all, it begs the question as to why there was a consultation in the first place.
The Regulators’ Code, states that
Regulators should have mechanisms in place to engage those they regulate, citizens and others to offer views and contribute to the development of their policies and service standards.
The crucial word here is “contribute”.
The OfS cannot continue to see consultations as a token opportunity for the sector to air their views. The burden associated with responding – all with huge amounts of content and the shortest of deadlines – is significant. All the time that universities are spending responding to consultations is time lost from developing their support for students and enhancing teaching and learning.
There is a further risk that if the OfS does not listen to the sector, changes will be made without regard for potential pitfalls. It is in the interests of everyone – the sector, students, and the OfS itself – for regulation to be good regulation. This means listening to the people who are closest to the issue.
Meanwhile, I wonder how everyone’s doing on their consultation response to the new access and participation plans…