What fresh hell is this?
Adverts for (English) university courses are going to be required to include comparable data on drop-out rates and the proportion of students who go on to graduate jobs or further study.
All forms of advertising – print, TV, radio, TikToks, animated gifs on the UCAS website during clearing, those teddy bears you give out on open days – will have to include the data, with the aim that students have useful information to make better choices about their post-18 study options.
Ministers argue that in the recent HEPI/Advance HE Student Academic Experience Survey, fewer than 6 out of 10 students said they’d make the same choice of course and university.
So this new approach, says minister for further and higher education Michelle Donelan, should help ensure that students have easy access to core data about their course prospects, helping them to make the right decision for their future.
Nick Hillman, HEPI director, says “the decision will leave many vice-chancellors wondering whether their institutions are as autonomous as they thought they were”. Free? To hide these essential truths from students? What kind of freedom is that?
Living in a shotgun shack
If you cast your mind back to February, you might recall the moment when it emerged that Gavin Williamson’s push for PQA was being quietly dropped – and as cover for that decision, Michalle Donelan used a speech to a UCAS event to instead advance an agenda on course quality transparency.
Two “market signalling” components were in the mix. One was the revamped TEF, which the Office for Students (OfS) is still crunching consultation responses over, and the other was about adverts – introduced using this astonishing analogy:
I expect many of you here will be getting public transport home today, and chances are you will see an advertisement for two things on your way home: credit cards and universities.
When you look at the credit card advertisement, you’ll notice that no matter what the sales line is, or how appealing the wider terms, the APR is written in black and white at the bottom. This information is there because of a conscious decision by government to ensure that consumers can make informed decisions before they make such a significant financial and time commitment.
But then glance over to the university advertisement next to it. You will notice that in sharp contrast, bold claims about career enhancement and graduate salaries are not backed up with the real information, despite the financial exposure of most courses being greater than most credit limits. And for anyone with the data to hand, the potential for students to be misled could not be clearer.
I said this at the time, but once again for those at the back. The minister who just a fortnight before that had slipped out a statement on a Friday afternoon revealing she was retrospectively worsening the terms of student loans used the analogy of financial services regulation to castigate universities for misleading students. You couldn’t make this stuff up:
Just like a credit card advertisement including information about APR, university adverts will reflect the need for students to understand where a course can take them, and give them the information they need to choose the course that fits their goals.”
What we now have is the “non-statutory guidance” underpinning that announcement, and it in many ways makes a bad announcement even worse.
Behind the wheel of a large automobile
It won’t have escaped your attention that the two data points in play here are those from that OfS “Proceed” wheeze – here DfE argues that while this data is publicly available, as things currently stand, it generally requires some inside knowledge and a certain amount of persistence for prospective students to access it.
So to address that, the basic expectation is that as of nowish, performance rates in the two metrics at both provider and subject level should appear on all adverts for courses:
- The data should be the data for full-time UK domiciled students at higher education providers in England.
- Higher education provider, in this context, refers to those providers registered with the Office for Students.
- The courses and subjects in scope are for first degree students (including integrated masters) only.
- Foundation degrees and postgraduate degrees (with the exception of integrated masters) are excluded, as are degree level apprenticeship standards.
- Courses where the majority of students are part-time, and/ or where the majority are not domiciled in the UK are also not in scope.
- The data presented should be at the level appropriate to the advertisement. If the advertisement relates to the provider as a whole, provider-level data should be used. If a course or subject is being advertised, the data presented should be for the relevant subject grouping, unless subject level data is not available in which case provider-level data should be quoted instead.
Water dissolving and water removing
Once you’re clear on what you have to tell students, you then have to have a fiddle about with fonts:
The data should be positioned prominently on all institutional and subject specific advertising. We would suggest that the font size for the data should be of the same size as that of the main body of the text, though it could be of smaller size to the headline. It should appear in a prominent position in the opening lines of any advert. Comic sans may not be used, but Arial Rounded will be permitted. And we do love a bit of Impact here at DfE.
In hard copy, DfE says that a note “source: Office for Students Proceed Data” with URL for the appropriate hyperlink should appear at the bottom of the text. And in the case of digital advertising, this note could be provided through a hypertext link. And where the advert carries a link that takes a viewer to a university website or landing page, that page should contain a more detailed description of what the data means.
- On webpages, the data should be displayed in a prominent position on the main web page for each subject or course. A reasonable test of this would be that it can be seen on landing without having to scroll down.
- On social media, the principles in the guidance should be followed to ensure the data is clearly seen in each case.
- On the TV or Radio, data should be quoted in any script that is used for advertising on TV or Radio.
- And amusingly, messaging from influencers (where they are being paid in cash or in kind to promote the provider or its courses) should also be accompanied by the appropriate data, using the text suggested.
The good news is that anything signed off or printed already is fine – but the expectation is that this will start happening now.
There’s also a finger of fudge in the guidance over joint honours ads, new courses, and small and therefore suppressed data.
And for the avoidance of doubt, DfE is asking that providers act on this guidance voluntarily in all new advertising – though it will be monitoring the level of take up, and if that proves to be insufficient, there will be consideration of whether this should be made mandatory.
There is water at the bottom of the ocean
I just despair sometimes.
There will be plenty of people on Twitter condemning this as neoliberal or wherever, but let’s imagine, as I like to do, that this is a good idea in principle – and so try to evaluate it on its own terms.
The links to Proceed data that DfE is telling providers to use are from December 2020 (minor corrections a few months later), because OfS hasn’t produced a new Proceed dataset since.
In that dataset, Creative Arts at Bath Spa has an 80% completion rate and a Progression rate of 70.5%. Those scores will almost certainly have changed in the intervening period – but DfE says use these. Maybe you decide to use both depending on whether the new numbers would make you look better.
Now let’s imagine that you’re a marcomms supremo at Bath Spa working up an ad campaign for your BA (Hons) Fine Art course. DiscoverUni records the Employment (Progression) rate as 90%, so presumably you’d be keen to not only do as DfE says – use the Common Aggregation Hierarchy level 2 groupings for subject, and the university-wide figures, but also the Common Aggregation Hierarchy level 3 scores for the actual course you’re actually advertising whose Progression rate is actually on DiscoverUni.
If on another course the data that DfE says you should use voluntarily – that’s old and at the wrong aggregation level – makes your course look better than it really is on completion and progression, you might reasonably ask whether using that actually misleads students about the course you’re advertising.
You may ask your solicitor that question too, since misleading consumers would be a breach of the Consumer Rights Act 2015.
You may ask yourself why the versions of the two metrics are different in definition to the metrics that OfS is proposing to use in B3 regulation – metrics which will be published as a public dashboard in two months time.
You may ask yourself whether you’ll be allowed or encouraged to put some bang average scores in small-ish writing next to your TEF Gold award if you get one.
You may ask yourself whether you’ll be allowed or encouraged to put some excellent scores in large-ish writing next to your TEF Bronze award if you get one.
You may ask yourself what a student who lives locally in Bath and can’t afford to move house to “board” at another provider is going to do with the data anyway.
You may ask yourself whether Regent College – who now has Gavin Williamson as a paid advisor – will be exempt advertising the fact that not one 2019-20 graduate got a highly skilled job, and only 15 per cent of its graduates are in full time employment.
You may ask yourself how on earth you’re going to persuade those international agents you use to do this when we’re not far off abandoning collecting graduate outcomes data from international students anyway.
You may ask yourself if anyone at DfE has read this comprehensive review of the “Key Information Set” and Unistats, or if there’s any joined-up relationship between this project and the OfS strategy on provision of information to support student choice.
You may ask yourself why DfE is making you highlight outcomes you often can’t control when it’s done nothing about providers making and keeping promises over the stuff they can control.
You may ask yourself whether anyone is actually going to do this when friends and colleagues in Scotland, Wales and Northern Ireland certainly won’t be.
You may ask yourself “How do I work this?”
You may ask yourself “Where is that large automobile?”
You may tell yourself, “This is not my beautiful house.”
And you may tell yourself “This is not my beautiful wife.”