Why does it look like more than 30 eligible English institutions are not entering TEF 2? And why did six eligible institutions actively opt out of TEF 1 – a competition that required them merely to continue existing?
The short answer is: we don’t know. We aren’t even told which they are. Not only did six institutions opt out of TEF 1, an exercise which would have automatically given them the scope – but not required them – to raise fees, but at least two significant alternative providers have dropped out of TEF 2 as well.
We’ve been working to get to the bottom of what’s going on with TEF since its first announcement and as the exercise has grown in complexity, so has the scope for oddities, exceptions and confusion.
It’s all about the money, money
TEF 1 (the Teaching Excellence Framework ‘year 1’, for fee increases for 2017/18) was a strange enough exercise. If you blinked, you probably missed it. 430 English institutions, simply by dint of having to be in good standing with QAA, were permitted to increase their fees up to an inflation-increased limit of £9,250 (the higher amount) or to £6,165 (for those able to charge only the basic amount). It was a smart strategy on the part of the government: few were likely to turn down the uplift in fees in return for not having to do anything, and, once in the TEF, they’d stay in the TEF. Or so the theory went.
The announcement was spotted by almost no-one when the eligibility list came out in early July last year, or when it was finalised in early September. Even though gov.uk doesn’t save earlier versions of documents (poor document management at gov.uk being an issue we return to), the internet generally does, which allows us to compare the two lists.
The following institutions were initially described as eligible for TEF 1, but were omitted from the final list:
- Barking and Dagenham College
- Bournemouth and Poole College
- GSM London
- Lakes College West Cumbria
- Regent’s University London
- South Thames College
As far as we can tell (hampered by poorly presented data from the government and QAA), none of these institutions stopped offering HE; none were subject to a QAA judgement that would have prevented their entry. They each opted out, for their own reasons, by the July deadline. They remain eligible for TEF 2.
For the FE colleges on the list, fees are currently lower (some as low as £5,000 per year) than the permitted threshold and so entering TEF would have had no benefit. However GSM and Regent’s are both major alternative providers and part of Jo Johnson’s vanguard of a new breed of institution – his Byron Burgers if you will – so their not entering TEF is eye-catching. We asked them why and confirmed that as well as not entering TEF 1, neither went forward with TEF 2.
Regent’s University London told us that is it opting out the exercise on principle. Prof Aldwyn Cooper, Regent’s vice chancellor, citing wider criticism of the TEF in Parliament and the commentariat, said: “We remain concerned that the current metrics, and those proposed for use, will not be a reliable proxy for real teaching excellence.” He also pointed to a lack of historical data being available with the institution stating that Regent’s is participating in “NSS for the first time this year, [and] we do not have the historical metrics or operational experience to feel confident about outcomes.”
GSM told us something similar, and on TEF 1 a spokesperson said: “Given the available data and the fact we have no immediate intention of raising fees, we decided to opt out of the TEF at an early point rather than to enter and the have to step out at the second stage.”
They are more supportive of the exercise in general and told us that they “do plan to enter at a future point when are satisfied that we have a data set that genuinely reflects where we are as an institution.”
Other curious cases involve St Mary’s University, South and City College Birmingham and Henley College Coventry – all failed their QAA reviews by not meeting the expectation for enhancing students’ learning opportunities. In all three cases, they are now fully compliant, but the compliance was signed-off in June 2016 – after the 18th May deadline stated in the White Paper. Therefore, had the deadline been applied, they would not have been eligible for TEF 1. None of the providers appears on the provisional list, but all three have made it to the final list and have their place on the statutory instrument (the list that really matters for the purposes of accessing student loan funding).
While it seems reasonable that the providers, which are all judged ok by QAA and missed the deadline by a matter of a few weeks, should receive the TEF 1 status, this explicitly contradicts the White Paper of May 2016. The quality requirements for TEF 1 are outlined in an annex and – see p83 – there is a clear statement that it would be too complicated to make provision in cases (like these) where a positive judgement was due but where the sign-off hadn’t been received.
When asked about why this was allowed, a Department for Education spokesperson said “The new Teaching Excellence Framework (TEF) will drive up the standards of teaching at university and it is encouraging that we have recently seen almost all English universities apply for Year Two of the TEF.
“There were a number of institutions who, in accordance with the process publicly set out by the department, queried the fact that they had not been included in the provisional list of eligible providers for Year One of the TEF. After careful consideration of each of these queries, the decision was taken that several should be included in the final list of TEF eligible providers. We are unable to provide detail on these individual applications.”
So it appears that if you make the rules, you get to break them too. This may not be problematic in an almost universal paper exercise, or even in a trial year of something marginally more selective – but as TEF gets more complex and the consequences start to matter, clarity on the rules of the game will become very important.
TEF 2: the next generation
There are four fairly straightforward requirements an English institution has to fulfil to be eligible for TEF 2.
They will have needed to:
- Have designation for student support at course, or provider, level, or be a fundable body [by Jan 17]. This information is available from the HEFCE Register.
- Have a published access statement [also Jan 17]. This isn’t a high bar – a statement just needs to be published on the institutional website – it doesn’t even have to be approved by OFFA.
- Have the minimum set of reportable metrics over at least one year [by Oct 16] – if not a one-year Provisional TEF award is available. These statistics are NSS, plus HESA data, plus DLHE. In our calculation used having NSS as a proxy for this, reckoning that any institution organised enough to have NSS would be able to have the others in order should they wish to.
- Meet the QA requirement in their home nation [by May 17] – you could probably get this from the QAA website, but because QAA present their review data so badly we used TEF 1 eligibility as a proxy measure.
453 institutions met criterion 1 as of February 2016, 338 met criterion 2, anyone who wanted to met criterion three, and (as above) 435 met criterion 4 – those which met criteria 1, 2 and 4 numbered 320. Again, all this is for English HE providers – though providers in Scotland, Wales and Northern Ireland can enter TEF 2 (and indeed TEF 1), it simply represents a badge to put on their website and has no effect on fee levels.
We know that a comparatively small number of Scottish universities have opted in, and a smaller number in Wales have opted out, and none entered from Northern Ireland. The Open University, which works across all of the UK, has also decided not to enter the exercise at all, explained why in some detail, and indicated it may enter in the future.
When participation numbers for TEF 2 were announced by HEFCE, we learned that 222 institutions delivering HE in England had chosen to enter the full TEF. A further 65 institutions entered the provisional TEF, giving us a possible total of 287 entrants from England – this is a best case scenario as we assume that all provisional level TEF entrants are English even though HEFCE has told us a small number of Welsh and Scottish institutions are included.
So this gives us 33 institutions in England that have not entered TEF 2 despite being eligible. With notable exceptions in the Open University – and now Regent’s College and GSM – we don’t know which institutions they are, although HEFCE and the government clearly do.
If the government is to use the high number of entries to the TEF as evidence of a success story (which is fair enough), it also seems fair that we should be given a list of who the entrants are. Otherwise, how can we or anyone else judge the ultimate success of this totemic new part of UK higher education?
Additional reporting by Team Wonkhe.