If you’ve been engaged in the higher education policy landscape in the past few months you will know that in July QAA announced it would no longer consent to being the Designated Quality Body (DQB) in England beyond 31 March 2023.
This decision was driven by the need to maintain our compliance with the European Standards and Guidelines (ESG) and therefore our position on the European Quality Assurance Register (EQAR). It was our desire to keep pace with ambitious international practice rather than prioritise scrutiny of the baseline. We were unable to do both.
If not us then who?
While generally sympathetic to our decision and the motives behind it, the English sector has understandably been concerned by this development. Many institutions and mission groups have been asking us what happens next both for the DQB functions and for QAA in England. As Paul Greatrix’s recent Wonkhe blog rightly pointed out, we are now in the “strange position where the only body which appears to be capable of acting as the DQB has decided it no longer wishes to do so.”
The DQB was a role enshrined in the Higher Education and Research Act (HERA), to enable an independent quality body that held the trust of the sector to review quality and standards on behalf of the regulator. Recently the Office for Students (OfS) confirmed that – at least on an interim basis – the regulator would be taking on the DQB role itself, a move that I know many in the sector will see as ominous.
OfS also indicated that it plans to take in-house the external quality assurance for end-point assessments in degree apprenticeships, even though the function does not statutorily have to be carried out by the DQB. QAA has done this work to date, and we have expressed our willingness to keep it.
We’ve published a bulletin that outlines the work we will complete as DQB between now and next March, as well as new transparency information about the work we’ve completed in the role. It provides some extra context to OfS’s recent publication of its operational measures explaining how long it takes to make regulatory decisions. While QAA’s reports have been provided to the OfS in a timely fashion, the resulting regulatory decisions appear to be taking a long time to materialise. Indeed, we understand that providers have experienced similar delays in referrals being made by the OfS to the DQB – meaning the registration process has been lengthy for many smaller providers.
To the baseline, and beyond
Since we announced our decision, some have feared that QAA might somehow “pull out of England”. Others have characterised it as QAA’s functions “reverting to OfS”. I want to be absolutely clear: QAA’s core activity as the sector’s independent and impartial expert quality body continues unchanged in England as elsewhere. The DQB role has been a discrete, ring-fenced role within QAA. Our work in England existed before the DQB role and will continue after it. Indeed, without the constraints of the DQB role we will be able to deliver a richer membership offering above the baseline, as well as provide new services to English institutions to support them to navigate the quality policy and regulatory landscape.
And of course our cross-UK work on the UK Quality Code, Subject Benchmark Statements, and the Frameworks for Higher Education Qualifications, will remain. Those UK wide reference points, along with the Credit Frameworks, including the one for England, are vital for the coherence of UK higher education and its international perception. For as long as they are valuable to institutions, we will continue to support the sector with them.
Crucially, for as long as the work of the DQB and the OfS focusses on baseline standards alone, there will always be the need for an organisation to encourage collaboration above the baseline. There is innovative, creative, high-quality provision being delivered across the sector all the time and it serves nobody to keep that best practice hidden under a bushel of bare minimum.
In the interest of students, QAA will always look beyond the baseline, recognising excellence and highlighting areas for improvement in England, across the UK and internationally. The enhancement services that QAA will offer to institutions in England can also help bring them in line with internationally recognised quality standards, giving confidence to international partners of the excellent, world-leading and high-quality education provided.
What’s that coming over the hill?
In the longer term, it is difficult to see how a future DQB with the expertise required could undertake the role without meeting the same obstacles we did. Clearly, the interim arrangements whereby the OfS takes the assessment functions intended for a DQB in-house are not sustainable in the long term, not least because the sector is (in our view, rightly) concerned that OfS lacks the expertise to carry out those functions.
Even if an independent successor as DQB is identified and appointed, without reform to the system, the key problem remains: English higher education will not be regulated or assured in a way that is compliant with international norms of good practice. The effect of that isn’t immediate, and while the vast majority of the English sector sits well above the baseline, we will soon notice diminishing faith in how robustly English higher education is assured and standards maintained. This could cause international stakeholders to question whether England is a suitable destination for international students, particularly those sponsored by their state.
While that might be music to Suella Braverman’s ears, it is not clear to me how much the OfS or indeed the wider Government are concerned – but they should be. In the longer term, non-compliance with international standards may make international partnerships difficult to form or maintain; and could even impact on mobility of staff and students, mutual recognition of qualifications; and even international employability, post graduation.
Perhaps then, Paul Greatrix’s suggestion that it might be helpful for the Secretary of State to instigate a review of quality assurance arrangements in England with a view to developing a rational, sustainable model seems eminently sensible. Now that the recent chaos in Westminster has abated, perhaps we’re moving towards an environment where that could happen. We watch and wait.
What an unholy mess the OFS has created here – and entirely of its own making with no good rationale or justification. The sector and students deserve far far better.
As a very minimum this demands a public response from OFS, but it seems unlikely on current behaviour.
If it does come expect justification based in the arcanely convoluted and yet still strangely meaningless system they have established.
Observers instead should look closely at the senior team at OFS and ask where exactly the sector expertise is? It seems largely (entirely?) absent.
And remember that as much as justification may come in regulation-speak and gvmnt infected double-think the reality is an organisation that has engaged for years now in a south west corridor agency turf war for little reason beyond desire for self preservation and domination of the regulatory space.
A more sensible approach was (and still is) always available, and they could have saved themselves huge efforts as well.
I was hoping this article would help me understand where English quality assurance regulation has diverged (or will be doing so) from international quality assurance standards. However, it didn’t, and so I have to be honest and say still don’t completely understand why QAA has withdrawn from the DBQ role. What will we be doing in regulating HE in England that is so different from everyone else?
Suggest reading this https://backend.deqar.eu/reports/EQAR/C74_QAA_ExtraordinaryRevisionOfRegistration_Update_bwtcIIy.pdf
Thanks for that link, Koala, very helpful.
Two key issues are lack of publication of reports and lack of involvement of students on quality review panels. Both of these were mandates laid down by the OfS. The latter is particularly baffling given they’re called the Office for Students.
And by implementing OfS restriction on students on QA inspections and not publishing the reports, QAA compromised its independence – it is a clear standard in the ‘Bologna process’ that QA bodies must be allowed to act free from interference by government. I may be wrong, but I think also a requirement for the DQB under HERA 2017.
England had also diverged from the UK. The OfS initially only regulated at the basic ‘common practices’ level, whereas the rest of the UK uses the full extent of the Quality Code.
But to return to the central suggestion – that a fundamental review of quality assurance arrangements is now needed – the answer clearly, surely has to be a resounding yes.
But expecting that to be led, and led well, by Westminster or for clarity to emerge now from Westminster…..well frankly that is for the birds.
The sector – through its representative bodies – itself needs to grab hold of this agenda and set out and push hard for alternative proposals for a system that can still meet international standards. It is as much a dereliction of their duties that they have not clearly done so so far – representative bodies have an obligation to protect the reputation of the sector they represent. To allow this to have to got to this stage is a clear drop of the ball by them also.
It is also surely time for the national audit office to take another look at OFS.