OfS begins second round of consultation on future TEF quality assessments

The much-anticipated Teaching Excellence Framework (TEF) details have landed in the form of a second round of consultation from the Office for Students, setting out the final version of plans for quality assessment of English higher education providers from 2027–28. The consultation runs until 28 January 2027.

Some key elements of the future TEF were already decided following the first round of consultation – you can brush up here on what those were. The main question resolved at that point was whether a Bronze award signals quality at or below the sector threshold standard, with OfS conceding that Bronze award holders should be considered as meeting the quality standards, not falling short.

The big change for the latest round of consultation is a proposal to make the TEF award voluntary. OfS is proposing that all registered providers be assessed for quality that either reaches or falls short of a minimum standard, with an outcome judged as being either satisfactory or unsatisfactory – with satisfactory being in practice equivalent to a Bronze TEF. This baseline assessment will include providers that haven’t accrued enough data to enter the TEF, though they may be able to enter in one category.

Those that throw their hat in the ring for a TEF assessment are incentivised to do so by the rewards on offer for those scoring Silvers or Golds – tuition fee uplift, permission to apply for or enhance degree awarding powers, access to public funding such as the SPG, though much of this will be subject to further consultation. Those with an unsatisfactory baseline quality rating or who are so deluded as to voluntarily enter the TEF only to emerge with a Requires Improvement rating will be required to reduce student numbers by 10 per cent annually, and will be subject to earlier assessment and most likely further regulatory scrutiny. OfS is seeking views on whether it should apply a blanket restriction of this sort, or apply restrictions on a case by case basis.

A quick reminder: providers entering TEF will be given separate student experience and outcomes awards, with no overall rating. Those sitting on satisfactory or Bronze will be restricted from further growing their numbers and re-assessed earlier, but in a tweak to the planned itinerary, those with a mixed Bronze/Silver or Bronze/Gold award will not be subject to any restrictions. For some providers it might be a fine calculation whether to go in for TEF at all.

There will also be some revisions to some of the B conditions to accommodate the new system – B conditions will now refer to “satisfactory” quality rather than “high” quality, B3 will now include a requirement for providers to “deliver positive post-study outcomes” (though the assessment of that element will be more nuanced than in the past) and B6 relating to participation in the TEF will be updated.

Overview of the process

All providers will be assessed over a three-year period, beginning in 2027–28. Selection for earlier assessment will be influenced by a range of factors, including those with lower current TEF ratings, availability of data for assessment, and risk to quality. OfS will also take into account factors like whether you’re having a DAPs assessment at the same time, or whether you’re in the middle of a merger, or trying to assess you and your partner institution at the same time, but these will be given lower priority.

In timing obviously intended to respond to criticism of the short turnaround time for the last exercise rather than to banjax a swathe of summer annual holidays OfS will communicate to the cohort marked for assessment at the end of July and providers will need to say whether they want to be assessed for the TEF within two weeks. Provider submissions will be expected by mid-December, and student submissions by the end of January, providers will be informed of outcomes the following July, and those with a Bronze or Requires Improvement will have a month to complain about it. Final publication of outcomes will be in September, unless you have complained in which case it will be the following January. Either way you’ll be obliged to publish your outcomes on your website, and OfS will also publish the outcomes along with an assessment report explaining why it made the decision it did.

As well as the various goodies on offer, your outcome determines when you next get reassessed – for Gold it’s five years, Silver, four, satisfactory or Bronze three, and anything less than that, two years. If you’re consistently not satisfactory…well, you don’t want to know. But strong regulatory measures seem probable. There will be scope to request to defer your assessment if, for example, you’re right in the middle of merging.

But wait, there’s a twist – before you start putting together your submission to TEF, OfS will tell you whether its initial risk assessment has thrown up any issues that might mean you should be subject to an enhanced assessment, or diverted into a quality investigation rather than a straightforward assessment. That initial assessment will include the TEF data, plus whatever else OfS has on you – ie reportable events, notifications, “regulatory intelligence”, previous regulatory findings, information about size and shape of provision.

Those judged as being at relatively low risk can proceed with a desk-based TEF assessment; those with flags for enhanced assessment might need to be prepared to produce additional evidence or accommodate a visit from assessors. Undergoing enhanced assessment doesn’t mean you won’t ultimately get a good score, but you’ll have to work harder to provide the requisite assurance.

An enhanced assessment would most likely be focused in one of three areas for student experience: academic challenge/academic rigour; capacity to deliver quality; oversight of higher risk provision (such as partner provision). In student outcomes it’s most likely to focus on below threshold or below benchmark outcome data that applies to more than 20 per cent of students.

In good news, though, OfS only intends to charge you for the baseline quality assessment element, not for the TEF bit.

Franchised or contracted out provision will be assessed as part of the overall TEF assessment. Validated provision will be assessed separately and a rating of satisfactory or unsatisfactory awarded, but this won’t influence your overall TEF rating.

Data and submissions

The student experience criteria will have six equally weighted elements, each of which with a corresponding NSS metric, which itself is equally weighted with the provider/student submissions. All following along so far? The elements are: course content; course delivery; assessment and feedback; student support; learning resources and student engagement. NSS data will be from the previous four years, with splits by subject and student demographics, with both overall and benchmarked scores, in aggregate and separated out by lead and partner providers. To help expand the range of eligible providers OfS intends to bring undergraduate students on one-year courses into NSS.

The focus of provider and student submissions, OfS tells us with a touch of acerbity, should be on what students experience and how the provider or student representative body knows that, not on the institution’s policies, processes or activities. Guidance will steer on how assessors weigh the quality of evidence provided, particularly evidence of impact. Criteria for assessment will focus on consistency across subjects and student populations – defined as a rule of thumb as capturing around 80 per cent of students – and on evidence of enhancement. The student submission must address all six criteria but students are free to focus on areas of most interest. OfS sets out in some detail the expectation that the provider must facilitate a student submission, and not exert undue influence on student submissions.

Now to the spicy bit – student outcomes. OfS is proposing to revise its current approach to B3 to differentiate between during study and post-study outcomes. The former, including continuation and completion, will retain the absolute minimum threshold, with supplementary benchmarks to act as quality threshold guides.

Post-study metrics will now consist of a basket of benchmarked measures, with no absolute minimum threshold. The three measures will be graduate-level employment, graduate outcomes survey data on use of skills learned on the degree, and salary. Salary will be measured three years from graduation (the highest annual earnings in that three years) against the average for 25-29 year olds in the general population. Graduates in further higher education study will be counted positively. Non-earning graduates – incorporating, we assume, the small numbers of graduate NEETS – will not be included, on the grounds that reasons for non-earning may be unrelated to courses. All this will be benchmarked by student characteristics, subject of study and geography.

The provider submission on outcomes is likely to be rather shorter than student experience, and is expected to focus on contextual information not already taken account of in benchmarking, evidence of actions taken that have demonstrably improved outcomes, or explanation of highly distinctive institutional circumstances – or “the Norland defence” as we call it round here.

As in previous iterations of TEF, across the piece performance 2.5 percentage points above benchmark is taken as constituting outstanding/Gold-level performance, performance at or slightly above benchmark to be high quality, and anything below to be less than high quality, with judgements depending on just how low you are. There will be a new 95 per cent threshold indicating outstanding provision in absolute terms.

Assessment and award

OfS has decided it wants the actual assessment to be carried out by experts but that OfS itself should carry regulatory responsibility for ratings and awards. As such assessment teams incorporating academic experts and student reviewers as well as OfS staff will carry out assessments, and recommend ratings to a quality assessment and TEF panel constituted by OfS and consisting of two sub-panels, each chaired by a member of the OfS executive team, which will make the final awards and consider appeals. Assessors will obviously consider data and provider and student submissions, but are also free to roam beyond the scope of that evidence, and draw on other sources held by OfS, as well as in the case of enhanced assessments, additional evidence requested from the provider.

For many institutions, the overall process won’t feel materially different from earlier iterations of the TEF – you’ll evaluate your data, gather your supporting evidence, write up your submission – and maybe even ultimately be one of ten lucky institutions chosen annually by OfS to visit to gather evidence of exemplary practice.

The tricky element here is the enhanced review proposal – something that may cause some hearts to sink if it bogs down multiple staff in collecting vast swathes of evidence for weeks at a time, as some have reported of the experience of OfS interventions. The proposal in itself seems reasonable – where there is evidence of elevated risk, the review should intensify in parallel, that’s hard to disagree with. But these interventions will need to be focused, proportionate to the size and type of institution, clear about what evidence is sought and what constitutes sufficient assurance, especially if OfS proposes to conduct them at anything beyond a very small scale. And given the precarity of the sector right now, it could be prudent to plan for enhanced reviews occurring at some scale.

The questions of modular and postgraduate provision remain live – OfS is undertaking to develop indicators appropriate for assessing quality in both, and to monitor risks in the interim. Modular provision remains at a very small scale (though I suppose we should accommodate the possibility of rapid growth over the next three years, however unlikely that seems) and delivered as part of larger courses, so the risks there are probably manageable, albeit it’s a new kind of provision. It’s hard, however, to make sense of the idea that postgraduate taught provision gets a free pass for the next three years. This could be an area that OfS could consider a more creative approach, either requesting commentary on PG provision as part of the TEF submission, or a national PG quality review project that yes, seeks to develop metrics, but also explores some of the differentiators of PGT provision around student demographics, pedagogies, assessment, and types of qualification, giving a baseline for future formal quality assessment.

One final note – at time of writing we didn’t have access to the draft guidance published alongside the consultation or the associated data tables but these are expected on Thursday 5 November and we’ll update this addendum when they arrive.