The Quality Assurance Agency (QAA) will no longer consent to be the Designated Quality Body (DQB) in England, as of the end of the current year in office (March 2023).
The reasoning is straightforward – the work that QAA does in England, on behalf of the OfS, is no longer compliant with recognised quality standards – namely the European Standards and Guidelines (ESG) as monitored by the European Quality Assurance Register for Higher Education (EQAR).
For this reason, the QAA registration with EQAR was recently suspended – a decision that highlights international concerns about procedures in England, but has an impact in the many other nations (including Scotland and Wales) where QAA needs that EQAR registration in order to fulfil a statutory quality assurance role.
What does this mean?
After 31 March 2023, OfS will no longer be able to call on the QAA to perform statutory assurance functions – in assessing provider suitability for registration and degree awarding powers, and in activity relating to degree apprenticeships.
OfS will invite applications for the DQB role during this period – it is already in discussion with sector representative bodies on this. The upshot may be that DfE is asked to appoint a new DQB, or that OfS takes on the role itself. In either case the expertise and esteem that QAA has built up would be lost, though. Universities UK, as sector representative body, told us:
The new successor body must be independent and command the confidence of providers, students and employers. We look forward to working with the Department for Education and the Office for Students over the coming months.
QAA, more generally, needs EQAR registration more than it needs the DQB role. Though income is associated with the latter, it sees the work it does in Wales, Scotland, Northern Ireland and internationally as being more important to the future of the organisation.
From March 2023 degree programmes in England will sit outside any internationally recognised system of quality assurance. This may well have serious implications for providers offering joint programmes internationally – specific quality assurance would need to be sought (and QAA may be able to offer the required ESG-compliant type). It’s even possible that there could be issues with the recognition of degrees awarded in England overseas.
Does not meet expectations
The deregistration of the QAA at EQAR is the end point of a conversation that has been ongoing for some time. The issues stem from the restrictions that OfS has placed on DQB activity – breaching EQAR registration requirements on the involvement of students in assessment panels (ESG 2.4) and the publication of review reports (ESG 2.6).
QAA offered undertakings to involve students in all review activity, and to publish all commissioned reports – but were constrained in carrying these out by the Office for Students. It has even attempted to take unilateral action.
Students are currently only involved in a third of QAA assurance work as DQB, and the current OfS consultation precludes changes of this nature. Reports that lead to OfS regulatory decisions (for example, on registration) are routinely published – but those that do not remain private.QAA has assured EQAR that conversations on this were ongoing with England’s regulator, but disappointment has been expressed that there will be no change in the near future.
Hiving off DQB activity in England to an arms-length body also didn’t wash – EQAR noted that reviews conducted as DQB were available both on the new site and the QAA website, and was “not persuaded that the new configuration makes DQB an effectively distinguishable entity”.
Reading between the lines here it is not hard to reach the conclusion that the real EQAR concern is around independence. Can it be meaningfully said that QAA as DQB can make decisions about processes (and thus quality and standards) outside of the influence of OfS and DfE?
Scope and nature
The statutory activity of QAA as DQB in England has been largely limited to the Quality and Standards Review (QSR), usually employed in assessing providers who wish to join the OfS Register. Just 19 of these have been published to date – the last in November of 2020. As DQB it also has responsibilities to advise OfS on Degree Awarding Powers (DAPs), and on Degree Apprenticeships (DAs).
In the grand scheme of work that QAA carries out this is not a lot of activity and not a lot of income. Most DQB income arrives on a “by report” basis – the declining number of reports requested by OfS saw a decrease in regulatory income of almost one-third in 2021. These days most income comes from provider membership and activity outside of England. DQB subscriptions top out at just below £15k each year for the very largest English providers – additional fees are levied where QSR, DAPs or DAs reviews are carried out.
Other QAA activities – for example the development of and advice around the UK Quality Code, the Subject Benchmark statements, and work with professional, statutory, and regulatory bodies (PSRBs) are supported by a separate QAA membership – mandatory in Wales, Scotland, and Northern Ireland but optional in England.
Why does OfS not want students to have a direct role in quality assurance? Why is there so much reticence to publish quality assurance reports that are clearly in the public interest? Why does OfS want to deviate from international standards?
It’s all rather reminiscent of a dark period in the history of higher education in the UK called the quality wars. Then the disagreement was between those who sought a regulatory approach to ensuring that what happened in higher education was of the required quality and of the required standard, and those who felt that academic expertise was required to make these judgments.
QAA was an initially very unpopular attempt to breach this divide – conducting reviews at subject and provider level at the behest of the regulators of the day, but using academic review panels. The approach shifted to a single, institutional level, examination of quality assurance processes in the mid-2010s – Higher Education Review set global standards until the advent of the OfS.
The new regulator made a lot of noise about risk-based regulation and data – and the general assumption (from Ministers of State down) was that the designation of a quality body would ensure that when data and risk indicated that more intervention was required independent academic expertise (and, indeed, student expertise) would have a role. It is fair to say that this is not what has happened, and – despite measures to bring academics on to the review bodies for the OfS’ own subject review visits – it shows no sign of happening in future.
Quite who benefits from having a higher education system sit outside of recognised international standards is unclear. Some may be hoping that the reputation of English higher education will trump standards – but this feels like a pointlessly dangerous bet.