The Office for Students has a (new) plan

The Office for Students has published its third annual business plan – around seven months late. It covers OfS’ planned work from October 2020 to March 2021.

On timeliness we might reasonably cut the still fairly new regulator some slack – there has been the little matter of a global pandemic on.

But before we dig into what’s in here, we should reflect briefly on the format. In March 2018, we got a proper table packed full of detail – strategic outcomes, headline activities and detail on outputs and activities and when they would emerge. In March 2019 we got 24 work areas linked to the five strategic objectives each with operational areas and projects (outputs), outcomes and key performance measures for each one.

This plan is much much thinner and considerably vaguer than its previous iterations. The strategic objectives (that used to link to its three year strategy) are gone, key performance measures are conspicuous by their absence and the whole thing reads more like a students union’ officer’s manifesto than the operating plan for a regulator – with vague sounding sentences like:

We will ensure our staff have the right opportunities for learning and development”

Officially this is all because the pandemic disrupted its normal business planning cycle, and having handled aspects of the crisis it has now identified priority areas of work that it will progress in the remainder of 2020-21.

Frustratingly, it doesn’t address the progress that we might have expected to see on the 2019-20 plan – but we’ll return to that later.

In the next six months, then, we have eight of these “priority areas” – each with a bit of narrative (“What is the issue?”) and a sense of the actions we can expect OfS to take (“What will the OfS do?”).

And we’re back

Much of this is not news. In the first section on “reintroducing regulation” for example, we get a rehearsal of its letter back in July on the “phased resumption” of regulatory requirements, having paused much of it when pandemic struck – with a commitment to build back lighter now that the regulatory framework is established and the initial registration work is mostly complete.

We also already knew that OfS will be “identifying problems” with the quality of teaching and learning, and taking “regulatory action” where necessary, although we’re a little suspicious about the hill of beans that OfS may be attempting to die on here.

A commitment to publishing its second annual review setting out its view of higher education in England and its progress in regulating it isn’t hugely exciting, although there will be “an event to discuss the issues”, which in the absence of live music, cinema and theatre could be the highlight of the festive season.

We will be getting revised guidance on monitoring and intervention (including a revision to the fabled reportable events guidance), a relaunch of its consultation on fines and the resumption of other work on stuff like harassment and sexual misconduct – although on that all we get is a commitment to a new “timeline”, which does sound awfully like we could go another whole academic year without there being clear expectations on providers in this important area.

And whereas in July we were told to expect “regulatory guidance on the public interest governance principles relating to academic freedom and free speech” this autumn, here that is watered down to OfS “starting a conversation” with students, providers and others on its “emerging” regulatory approach to freedom of speech and academic freedom. Maybe government has plans of its own.

Quality and standards

We have written extensively over the months about OfS’ “B conditions” and how its agenda for those has been developing, with ever clearer signals that it would be applying “minimum standards”, judged through metrics, at subject/course level rather than just at provider level.

It all felt like government was getting impatient with OfS’ progress here over a year ago – Gavin Williamon’s pre-election letter to the regulator in September 2019 did some chivvying and all the political indications since have suggested that ministers would very much like to take credit for a subject area n a university getting shut to prove their mettle on “value for money”, and act as a way of introducing number controls to allow ministers to look good – “we’ve saved students from enrolling on courses with terrible drop out rates or employment outcomes”, that sort of thing.

Both the pandemic and the minor inconvenience of losing a major court case have slowed all of that down even further, but brace brace for this agenda’s return. DK has already written about the development of metrics that could be used here, and we are primed to expect a consultation on this (that in part responds to the issues in the court case) imminently:

• Improving the clarity of the minimum baseline requirements that apply to all providers
• Raising the bar for all providers and addressing poor quality at subject level
• Bringing new sector-recognised standards into the regulatory framework to ensure that we can take regulatory action where these standards are not met
• Expressing our requirements in a way that works for providers seeking registration that do not have a track record of delivering higher education
• Aligning our policy approach and use of data with other regulatory requirements, including the Teaching Excellence and Student Outcomes Framework (TEF)
• Monitoring compliance with the quality and standards conditions, and investigating any concerns
• Using enforcement powers where there is or has been a breach of quality and standards conditions, and escalating enforcement action where such a breach is serious or is not remedied.

Keeping access and participation on track

Again, much this we knew – the pandemic has particularly students supported through access and participation plans, it has prevented some access and participation activity at all stages of the student lifecycle, and providers have been allowed to:

shift their resources from activity that could not be delivered under lockdown to supporting the immediate imperatives of the most vulnerable students, focusing on student hardship and mental health”

…some moderate flexibility that DfE has gone on to proclaim whenever anyone has asked about any issue facing any student in any provider ever.

In the next six months, we’ll get guidance for providers to report on activity during 2019-20, progress made towards expectations in 2020-21 plans, and the impact the pandemic has had on these plans. We’ll also get an update to its access and participation dashboard, a process for agreeing changes to plans, some changes to the funding of the Uni Connect partnerships and changes to how student premium funding is allocated so that it hits the students it is supposed to.

One unexpected bit of news – OfS will explore options for supporting care-experienced students:

aiming for a common offer of finance, accommodation and support for these students across universities and colleges.”

That’s a highly unusual but welcome move and flies a bit on the face of the old “we won’t proscribe the outputs if you hit the outcomes” approach – we wonder if some political pressure has been exerted here and whether it’s the sort of thing that might become more common once Michael Barber departs.

Higher level skills to support recovery

On that note, there’s a strong sense of political priorities elsewhere in the doc. A whole section on higher level skills and economic recovery parcels up various little projects handed to OfS in the funding space – funding for the increase in students entering STEM, medicine, nursing, and allied health professional courses, the project to improve access and participation for BAME PGRs, work with Health Education England on increasing nursing students and that weird scholarship programme it’s running to support 2,500 taught postgraduates to re-train in Artificial Intelligence.

We’ll also get an analysis of flexible higher education participation for mature learners – which it feels like we’ve been promised before – as well as a separate and quite vague section on funding that merely commits to cracking on with its consultation on changes to its approach to funding, a terrifying yet also quite vague section on “market exit”, and a whole bunch of stuff on process (covering stuff like the bureaucracy review) and “effective operations”.

What’s missing?

In any big organisation’s three year plans, things fall by the wayside – some stuff turns out to be harder than it looks, priorities shift and morph and events like global pandemics and court cases get in the way. But it’s nevertheless worth looking back at iteration one and two to identify some of the main things now missing.

Version one promised “plans for championing activities by summer 2018 to focus on… access for white men from underrepresented socioeconomic groups”, an agenda that popped up at the Commons Education Committee just the other day, but not one we recall OfS going large on.

We were going to get “a topology of the diversity of the higher education sector”, drawing on information from the registration process and its exploration of providers that remain unregistered – and in fact, a whole section on “new and alternative forms of provision” promised “mechanisms to understand innovation” in the sector, a work placement measure beyond sandwich placements, an approach to removing barriers to provision of accelerated Degrees and even “quality dashboard” for HE apprenticeships – a task now handed to Ofsted.

Ironically we’ve had something of a flurry of new providers appear on the register in recent weeks, but publicly this whole agenda feels very much on the back burner. And we’ve already reflected on the differences in tone between the sorts of changes we were told to expect to the National Student Survey until recently, the direction of travel that DfE is trying to set and how that is playing out in this autumn’s review.

Taken together you do get the sense that a lot is up in the air – we’re still awaiting the response to Augar and the review of the TEF, there’s a white paper that may or may not advance a slew of agendas in particular directions, and Michael Barber’s departure will almost certainly deliver a replacement who may be less precious about regulatory design and even closer to the politics of the day. There’s also no doubt that subject-level outcomes baselines could yet turn into the single most interesting and controversial intervention yet, especially if it delivers the government’s value for money agenda.

But you don’t get any real sense that the workplan reflects the big issues facing the students whose name the organisation takes in vain. Can OfS justify almost anything it does as being in the “student interest”? Yes, of course. But does that mean it’s using its powers, funding and good offices to deliver on their priorities? It feels like there’s some distance to travel yet.