Quality assessment through the looking glass

At times, reading HEFCE’s Revised operating model for quality assessment has felt like going through the looking glass. Like Alice, I daresay I haven’t had enough practice at believing impossible things, but the week after we hear there will be an HE Bill, there is something slightly unsettling about the thought that the organisation determining the higher education quality assurance landscape to 2025 is about to be abolished.

So what are we to make of the new operating model? Is it an item on HEFCE’s bucket list, the administrative equivalent of skydiving into the Grand Canyon? Or is it the blueprint for a long-term approach to quality assurance under the Office for Students?

There are undoubtedly elements of the revised operating model that fit the future policy landscape described in the Green Paper, as well as the language it uses. Quality as an integral part of regulation; a risk-based system; the capacity to assure a baseline of quality for entry into the sector are all essential aspects of any imaginable future quality assurance regime under the Office for Students.

The focus on the student interest expressed in terms of assuring degree standards and their broad comparability plus the associated proposals to strengthen the external examiner system and the proposed reforms to degree classification algorithms all go to the heart of concerns raised by Jo Johnson in July last year.

The model is, of course, designed to encompass all providers but – that looking glass moment again – it can only cover alternative providers “in the future” because, as HEFCE remind us in a footnote, “The current regulatory framework for higher education in England provides statutory powers to HEFCE to assess the quality of education in those providers in receipt of HEFCE funding and those to whom HEFCE is considering providing funding. HEFCE has no regulatory power in relation to alternative providers seeking to enter the English system.” Despite that caveat, much of this document looks to have legs.

However, other aspects appear more problematic. For a start, and as Mark Leach has already commented, it is not obviously less burdensome and costly for the sector. Nor is it clear why you couldn’t have achieved a cheaper, less burdensome system without such wholesale change.

Take the extension of HEFCE’s five yearly assurance review (the HAR) to “check the evidence and processes used by the governing body to reach its annual statement on the continuous improvement of the student academic experience and academic output standards”. HEFCE say “It will be important to ensure on the one hand that the extended HAR is credible but on the other that it does not become a burden on a similar scale to the Higher Education Review.” Quite. Or you could just have asked QAA to propose ways to reduce the burden of Higher Education Review.

Secondly, HEFCE’s operating model does not make things simpler – and doing so is a major theme of the Green Paper and recent Ministerial speeches. When Jo Johnson spoke at the UUK conference last September, he mentioned the complexity of a PowerPoint slide illustrating the higher education landscape that he got in his day one briefing pack. HEFCE’s proposals for tendering multiple contracts would add more lines and boxes to that slide.

Would it matter if some of HEFCE’s proposals didn’t feature in, or even contradicted, the White Paper and an HE Bill? I’d argue that if this was the case, then the approach of BIS and HEFCE to transition to a new system becomes crucial.

If some aspect of the operating model really doesn’t fit, if a proposal clearly isn’t going to survive the creation of the Office for Students, then there should be compromise on both the substance and the timeline for introduction.

Perhaps the piloting could take a bit longer so that more lessons could be learned or learned more fully; perhaps the intended date of 2017/18 for full implementation of the operating model for quality assessment could slip. Whatever the Government’s final proposals are on quality assurance, HEFCE and BIS must handle the transition so as to minimise unnecessary disruption for institutions and students.

Textual signals in the Revised operating model are not encouraging: “In this context of wide-ranging policy development, careful consideration has been given to the appropriate timing for the next steps towards implementation of revised quality assessment arrangements. We have concluded that it is important to begin implementing the revised operating model now…”. This is prose worthy of a government consultation response, and translates as “yes we know all the good reasons why we shouldn’t but we’re still ploughing on regardless”. But if a central Budget announcement can be reversed within a week, I won’t give up hope just yet.