Proposed Quality Code how do I love thee not? Let me count the ways…

One of the nicest features of my role is that it involves working with opposite numbers across the spectrum of UK HE – all shapes and sizes, all nations, new and old, public and private. At the moment, though, there is a pretty uniform sense of frustration and dismay among colleagues at the proposals for a new UK Quality Code for HE, developed by the UK Standing Committee for Quality Assessment.

Why this, why now?

The current Quality Code has a number of problems. It is cumbersome, repetitive, lengthy, and difficult to navigate. However, I think you would have to turn over and read down to the bottom to find the Code on the list of challenges the sector currently faces in ensuring students have the learning and life experiences we want them to have. But not only is the Code under review, the consultation on its key content has already closed. The new proposals are not just radical, though: in sharp contrast with the current Code, the changes are being pursued with great haste.

Why hammer this nut?

The review is seeking to do good things; to shorten, simplify and restructure the Code. The current Code is essentially intended for hard copy publication, consisting of a book with discrete chapters. The review proposals would allow us to take advantage of new opportunities for improving usability, navigation and accessibility. However, these are fundamentally editing and design considerations.

The review risks chucking the baby out with the bath water. Its proposals dispense with fundamental principles that underpin how UK HE is run for the benefit of students. As such, it succumbs to a clichéd desire for a regulatory bonfire. It is reductive and feels crude. In trying to capture the things we should do on a single one-page table, its ‘expectations’ and ‘core practices’ tend to be too narrow and too rarefied – and consequently open to misinterpretation and thus misapplication.

We are told that remaining activities used in managing quality and standards will have the status of ‘Guidance and Advice’ – and thus no regulatory force. Furthermore, the fact that the Guidance and Advice are not yet available for consultation means we are effectively being offered a pig in a poke – something my grandmother knew better than to buy.

What’s being binned?

What’s absent from the proposal deserves attention. Foremost for me is the partnership approach that has developed with students over time, and is only referred to in purely transactional terms. It seems extraordinary that the initiative that has led to the establishment of the Office for Students omits reference to this partnership approach, given it is an essential component of the (healthy) UK sector. The Code should prioritise the principles of student engagement and opportunities for collective student representation – as these support providers in interpreting and understanding students’ views, champion the student interest, and play a vital role in providers’ governance.

Basic good governance, in any sector, involves external scrutiny. Every budget, however small, is subject to audit of some form. The requirement for externality in academic decision-making – exercised through monitoring and review – also maintains standards in the sector. However, the draft Code lacks any explicit requirement for this for UK HE. Ironically, the work commissioned by HEFCE to strengthen the less-than-perfect external examiner system is passed over in silence. It is odd that the fostering of students’ capacity for critical self-evaluation, something that has been an explicit feature of HE programmes for generations, does not materialise as a necessary feature of HE itself.

The end of UK HE?

As a Scot, one of the more irksome proposals for me is listing quality enhancement as a practice that is ‘supplementary’ to good HE, rather than a core expectation. The enhancement-led approach to quality management is completely embedded in Scottish HE. Labelling it as ‘supplementary’ devalues its centrality to the Scottish system, and a feature that contributes to the strong reputation of our provision.

The same may be said for the Welsh approach. However, as I can hear my English friends correctly reminding me, Scotland and Wales do not own enhancement – and so the proposal would also sell-short efforts made by every UK provider to enhance what they do. But if a new Code comes at the cost of the Scottish and Welsh approaches, rather than support diversity the proposals risk eroding the global perception of UK HE as a strong and unitary entity – with consequences for England as well as the other nations.

However, the whole project is driven by an anglo-centric agenda, and not just as in the OfS’s lack of interest in enhancement. The proposals very much continue along the trajectory set by the 2014 HEFCE review of quality assessment, and its follow-through in the shape of Annual Provider Review and the TEF, in its determined focus on outcomes. This involves dispensing with any description of the processes that produce them. This begs the question if the process doesn’t feature in TEF, APR or HAR, where does it feature – if not in the Quality Code?

These processes and practices form a key part of what UK HE’s reputation is built upon. If it is not expected that the practices should cease, why not refer to them as underpinning strengths of the system? It is important that the world knows that we will continue to do this. The concern for our collective reputation stems from the facts that we compete in a global market and that current arrangements help secure the recognition of our provision by international accrediting authorities.

A whiff of Brexit

There’s also a slight odour of the spirit of Brexit isolationism. The absence of student participation in provision review (beyond feedback submissions), enhancement and, above all, externality, mean the proposals would not meet the terms of the Standards and Guidelines for Quality Assurance in the European Higher Education Area (ESG). This is critical: failure to conform to the ESG could ultimately put at risk UK student mobility in Europe, the recognition of UK awards and thus UK graduates employability.

A trim is all that’s required

Again, the current Code should be rationalised, but there is a trade-off between such deregulation and the collective reputation of the UK sector. I find the implied notion that the broad content of the current Code acts as a disincentive to new would-be providers to be misplaced and dangerous. In my experience, new providers are in fact only too grateful for regulation and guidance on process, rather than being forced to articulate quality and standards frameworks for themselves. Rather than stifling innovation, they are prerequisites of successful operation.  

Even the most established institutions make extensive reference to the Code in support of the quality and standards of their provision.  The present Code is lengthy, but the remedy is a trip to a good hairdresser, not to the guillotine. It is lengthy less out of pedantry than because the enterprise of higher education seeks to provide students with an experience that transforms their lives and is, consequently, correspondingly complex. Perhaps academic discursiveness turns out to be an important feature of the academic experience. Do our students not merit such concern?