Taking care of business – the OfS 2019-20 business plan

Our new regulator is growing up fast. Today sees the launch of Office for Students’ second annual business plan, setting out plans and priorities for the first year of regulation under the powers granted to it by the Higher Education and Research Act (HERA) and it’s second year of existence.

The plans hang under the three year strategy published last year – a short, reflective (and unsigned) foreword is congratulatory about the progress that has been made. But it’s not all been as smooth as these words suggest. We’ve also taken a look back at last year’s effort in order to determine whether we need to put a condition of registration on the OfS based on the quality of their planning.

Take Value for Money – one of the central four objectives handed to OfS in HERA. In early 2018, back when OfS was little more than Nicola Dandridge hotdesking out of HEFCE, almost its first act was to commission student-led research into the subject. That was supposed to inform the development of a “programme of student and stakeholder engagement” on VFM by last November to identify “what matters and why”, and then the production of a “value for money” strategy this year setting out how it would address factors which affect perceptions and how it would measure progress. Keen to know where the money goes, students were also promised “quantitative and qualitative analysis of providers’ transparency on institutional expenditure and value for money”.

Things have been curiously quiet on that front until now – in the new plan there’s no mention at all of that transparency agenda, and the VFM strategy overall is now not set to appear at all until December 2019. Tantalisingly, we are told that this will be measured through “student and key stakeholder perceptions” and – date for the diary – we are promised the first annual “value for money report” by March 2020.

It’s always been a bit embarrassing that the office with students in its title has so far been so far away from requiring of itself the sort of standards of student engagement that it expects from providers on things like the TEF or Access and Participation. Again, a student engagement strategy going beyond its student panel was promised this year, but in the new plan is pushed back to January 2020. You could say that it’s not yet fully met this requirement, and so is under enhanced monitoring by students and their SUs in the year ahead.

We heard you liked NSS, so…

Then there’s student satisfaction. In 18-19 we were promised both an exploration of new measures and monitoring tools “including a social media scraping methodology” and a look at a “more frequent survey that captures views of students in different years”. Some will be pleased to learn that instagram algorithms have disappeared, and the rest is still there but also pushed back.

However, there’s slightly firmer news of an expanded and revamped national student survey. No longer content to keep the fun for third years, the plan suggests an “all years” NSS will enter development alongside a postgraduate student survey. To the best of our understanding, neither of these will be directly comparable to the current NSS, which may even continue alongside these innovations. Students will surely be delighted that so much effort is being made to take account of their expressed views – or at very least that free cake will be available outside of the traditional week in March of the final year.

This is a huge step. On the one hand it demonstrates a seriousness about student feedback that some have looked in vain for, but on the other hand it does not address the many well-documented issues with the current way the NSS is used and collected. Simply adding more data to the pile is unlikely to give us more insight – feature creep has seen NSS move from an information source aimed at prospective students to, via TEF, a tool of regulation. And, to be honest, the cracks are beginning to show. The politicisation of the survey has led (visibly) to boycotts and (invisibly) to what we will kindly call strategic approaches to encourage survey completion. We need to fix these issues, if we can, before any expansion is considered.

Whatever turns up will surely be featured in the much-anticipated Unistats replacement, now due in September 2019.

Not ideal

Off the back of an initial batch of student protection plans that even Michael Barber politely described as “not ideal”, we get a commitment to develop new guidance for providers on student protection plans at some point in 2019-20. That’s a pity, as it almost certainly means that there won’t be any significant change to SPPs by this September – the second academic year in a row when large parts of the sector will be restructuring provision and when therefore student protections in the event of a shutting of campuses, courses or their material components will be needed the most.

There are some interesting items from ministerial missives to the regulator that don’t seem to be making a mark on the plans being hatched in Bristol. Sam Gyimah has asked that OfS “promote student engagement and representation at provider and sector level”, but apart from its own strategy there’s no activity promised here. Ministers had also requested that OfS take a “keen interest” in how providers meet their statutory obligations relating to the “transparency, accountability and finances of students’ unions”, but again no sign in the plan.

There is subtle movement on student equalities, wellbeing and harassment. Like providers themselves, OfS has been addressing these wicked problems by throwing money at the wall to see what sticks – but that scattergun approach (and leftover HEFCE catalyst funding) can’t last forever, and so we do get the development and delivery of OfS’ “sector regulatory role in relation to student wellbeing” – although notably no action what probably should be OfS’ provider regulatory role in this space. Some will argue that this is as it should be, but there are plenty of students in parts of the sector where it’s highly unlikely that harassment policies and mental health services even exist, let alone are good enough.

The promise of “a new set of activities to support the embedding of effective practice within providers” around access and participation will surely set ears twitching at AdvanceHE. Historically we’ve seen substantial efforts (and funding) devoted to the collection and dissemination of good practice – organisations like the old Equalities Challenge Unit and the Higher Education Academy, not to mention the “good practice” strand of the Office for Fair Access’ work. It has felt as if it’s been all targets and no support in access and participation – hopefully some of this will redress the balance.

Regulation for everyone

Ministers have also asked that OfS “drive communications actively to raise awareness among students of their rights as consumers” and “assess the availability of impartial advice and support for students”. In the business plan this gets watered down into “evaluate and report on the advice available to students about their rights as consumers”, which may then lead to action in 2020-21 – a shame given that as far back as February 2018 OfS recognised that awareness of rights and access to advocacy were issues.

For students without a proper SU, in its analysis of responses to the consultation on the draft regulatory framework OfS did point providers to OIA’s good practice framework which recommends that “where it is not practicable to do so internally, providers should consider making arrangements for students to access support services at neighbouring institutions, partner providers or other local community services”. Guess what – we are yet to find a single one that has.

And OfS are planning to make some inroads into the quality the providers it doesn’t regulate – all in the name of quality and choice for students. This might sound counterintuitive, but the initially floated “Basic” category of registration would have seen many of these having at least a nominal relationship with the regulator. It’s not quite the development of an understanding of providers and students in the non-registered sector promised last year, the OfS is merely looking at quality assurance for level 6 and 7 courses, and – gnomically – the “incentives” for non-registered providers. We assume this latter refers to incentives not to register, but it is perhaps a step along the way towards OfS becoming the Office for all Students.