In October the UK Standing Committee for Quality Assessment (UKSCQA) launched a consultation on the review of the UK Quality Code. The changes envisaged in this consultation build on a review already in hand by QAA, based on feedback from the sector over the last year. But in an evolving landscape, change to the Code is also needed so that it can continue to be used as part of UK-wide regulation across the sector.
This consultation is, therefore, an opportunity to make the Code fit for purpose in a new world and to preserve its UK-wide character. UKSCQA’s leadership of this consultation reflects the importance of the co-regulation underpinning the Code, which its strategic oversight aims to strengthen. The committee’s membership spans sector and student representation, with the four UK funding bodies, and with other regulatory partners.
In origin, the Code was created with the sector, chapter by chapter. But it also has to be fit for use in regulation across all of the devolved administrations – and would be inoperable if it were not. For that reason, for England, the much larger Regulatory Framework Consultation published in October and running alongside this consultation, also sets out a fall-back position – to be sure, one that is less desirable from a number of perspectives – which would apply in the unlikely event that a version of the Code emerged that was deemed not to be suitable for regulation. The changes proposed, in the setting of an open consultation, seek to avoid this eventuality, which as Catherine Boyd points out (‘What’s happening to quality?’) would leave the four nations with a Quality Code that is no longer UK-wide.
So what are the changes? Structurally, the Code changes so that it can be used across the four nations of the UK. The expectations set out by the Code continue to be shared, and different arrangements expressing national positions converge at this overarching level, while spelling out the detail, articulated as practices, at the next level down. This convergence is important: the UK’s sector’s global reputation rests to a significant degree on being legible from beyond its borders as a single system.
This architectural change also allows different emphases, e.g. on enhancement which is at heart of the Scottish system. Enhancement is not part of the English regulatory framework (i.e. it does not appear as a condition of appearing on the Register), but it is open to English institutions to use the practices set out here, and the impacts on performance of doing so will be picked up in the TEF.
There are also important changes in approach. The proposals streamline the Code, reducing its bulk, and they place more emphasis on student outcomes. Parts of the current Code are quite transactional, suggestive of a ‘registry manual’ approach, for example in the stipulation to ‘position their qualifications at the appropriate level of the relevant framework for higher education qualifications’. The proposed new expectations – for example, ‘Students achieve standards beyond the threshold level that are reasonably comparable with those achieved in other UK providers’ – should be a better starting point for open discussion inside a university (or a faculty or department) about the quality of teaching and how it translates into student outcomes.
Hearing the student voice
And there should be no less scope to reflect the student voice or interest in the way in which the core expectations and Practices are taken forward: student engagement is a crucial element of any quality framework, as we have heard at the events run in connection with this consultation and elsewhere. We will be interested in hearing further the views of providers and student groups on how this can be emphasised in a streamlined Code. In other feedback, we have also heard views on enhancement, employability and externality. In addressing this feedback, we will be looking for ways in which the Code could more clearly support or inform in these areas.
Streamlining has wide benefits. The new expectations have been framed in a way that makes them more accessible to students, and new audiences including non-traditional student groups. And a shorter Code, alongside its accompanying guidance, will be of more use to the wider community of higher education staff, student representatives, students and the wider public.
Getting the audience right and making sure it is engaged was always important. But it is even more so in a new environment where the leadership and governing bodies, of institutions will have more significant statutory duties in respect of quality and standards. Here simplification is a pre-requisite for effectiveness, and for securing the agility and ease in internal communication that we will need to make proper assurance of quality a reality.
In the Quality Code and in the wider system we need an operation that is effective with a minimum of fuss, that eschews box-ticking and lets academics and institutions focus their energies on things that matter, and in particular the student interest.
We encourage all elements of the sector to engage with this consultation by midnight on 13 December.