Reading the recent press coverage of the launch of the Office for Students (OfS) has reminded me of the day in school when our French teacher, a French national, asked us the name of our country. Most of my Essex classmates could get as far as ‘England’ (and, that included a few chants of ‘En-ger-land!’, probably for his benefit).
It turned out that I was the only one in the class who understood that there was a difference between England, Britain and the UK, courtesy of having a Scottish father. This understanding has stood me in good stead since moving to live in Wales but I continue to be surprised at the casual disregard for devolution in so many areas of our UK press.
OfS is to be the regulator of universities in England only, and we look forward to working with it. Different arrangements will continue elsewhere in the UK.
As the regulator of providers of higher education in Wales, the Higher Education Funding Council for Wales (HEFCW) has long-established habits of working closely with NUS in Wales (NUSW). In 2012, Wales was the first UK nation to require every university to have a student charter written jointly with students.
The Quality Assessment Framework developed by HEFCW protects the rights of students as learners, rather than customers, reflecting a clear, and increasingly distinctive position of the Welsh government, one that does not place the market philosophy centre stage.
HEFCW’s title might make no specific reference to students but we see the protection of their interests as one of our key responsibilities. Our close work with NUSW is underpinned by a memorandum of understanding and we have enjoyed the benefit of their president sitting as an observer on our council for many years. They don’t have a vote, but they do have a voice, which works well for all of us.
The human touch
Looking after the interests of students, and the broader public requires that we have some idea what is going on. We have an Institutional Risk Review (IRR) process in Wales, through which we take a view, twice a year, on the key risk factors facing our institutions.
Much of this is informed by data, of course – the usual indicators of finance, quality, recruitment, etc. All of these, though, are lagging indicators. They tell us where our institutions have been, but not where they are now, far less where they are going. They are an important part of the picture, but they don’t tell the whole story.
Very often, when problems are showing in lagging indicators, it is too late. That is why we supplement our indicator-based analysis with a range of “soft” or human intelligence. In the end, institutions fail not because of the challenges they face but because of the way they face their challenges. We don’t ignore the numbers, but we do inform our risk assessment with informed judgements about the extent to which institutional management, and governors, are aware of their challenges and competent to address them.
This approach naturally absorbs more of our time. Gathering that soft intelligence takes a lot of conversations. To run a risk assessment system which rests on soft, as well as hard, indicators means we need to know our institutions well. That is not without its challenges. We have occasionally been accused of being too close to them. That goes with the territory for an intermediary body, but I am clear: knowing them well does not prevent robust intervention – it just means that intervention is more likely to be effective because it will be more timely and better informed.
From the top
There is also always a debate with the sector about how engaged and interventionist we should be, particularly in times of difficulty. Let’s be clear, institutional failure is rarely, if ever, a product of anything other than a failure of governance.
The consequences of such failure are most keenly felt by the students of the institution, and then the staff. There are broader consequences, though: failure damages the reputation of the system and has other impacts, such as increasing the cost of commercial finance.
It is in the interests of everyone in the system that the oversight machinery pro-actively seeks to prevent failure, rather than simply responds to it as an inevitable consequence of a market approach. Universities are not like start-up businesses, nor should they be. When I last discussed this with the vice chancellors in Wales, I asked them to raise their hands if they were planning to be in crisis in the foreseeable future. Unsurprisingly, no hands were raised.
That’s the point of course: the machinery we operate is not intended to burden providers, but to protect them, as far as we can, from the failure of others.
Reflecting back on my French lesson experience, higher education is devolved to the various nations of the United Kingdom. The systems and approaches are different, increasingly so, and we all need to be conscious of that.
They are all still closely related, though. The Welsh system is explicitly not market driven, but it is clearly recognised that we are part of a UK and an international higher education market. Across the world, the awareness of the distinction between the UK and its constituent countries is often no greater than that of my former classmates. To many of them, it is all one system (irrespective of whether they can distinguish between the UK and England, Wales, Northern Ireland, or Scotland).
In that context, we all bear a responsibility to each other and, as we move towards increasingly diverse arrangements across the UK, we will all have to find ways to meet the challenge of remembering that.