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The OfS Data Futures consultation: right answer, wrong question

Talk about the burdens of data collection needs to take into account how many agencies collect data from providers, says Andy Youell
This article is more than 2 years old

Andy Youell is Executive Director: Regulation at UCEM

Just before Christmas OfS launched a consultation on the HESA Data Futures programme.

The consultation sets out the options (preferred and others) for the model of student data collection that HESA is to adopt in the future. This is the latest step in responding to the guidance that the then Minister for Universities – Michelle Donelan – set out in her Strategic Guidance letter of 14 September 2020 which spoke about the significant burden that “termly” data collections would impose.

The OfS proposals would see the current plan for three annual collections reduced to two discrete collections with the first of these – the “in-year” collection – collecting a reduced set of data. Those with an interest in the history of higher education data cannot fail to have a wry smile at the idea of future collections using the model that HESA first designed in 1993 and operated until 2000 – when it was sacrificed on the familiar altar of burden reduction.

The proposal to reduce collections from three to two – along with the removal of a few fields – will reduce the burden placed on providers and thus earn OfS the required ministerial brownie points. But for the majority of universities in England, this “win” on burden reduction pales into insignificance when looking at the pain caused by the multiple silos of student data collections that they currently face.

Brave new world?

They say that a week is a long time in politics and, in the 65 weeks between the Ministerial guidance and the publication of the current OfS consultation, a lot has changed. The emphasis on higher-level apprenticeships to re-skill the national workforce – without burdening the Treasury – is now central to every utterance that comes out of DfE. Whether it’s in the context of levelling-up or “putting employers at the heart of the system”, ministers in England are increasingly following the lead of Scotland and Wales by focusing on a more coherent approach to FE and HE. This must be applauded.

Of course, the sector is responding to this challenge. Of the 113 Universities on the OfS Register 92 are now listed on the ESFA Register of Apprenticeship Training Providers. So, while OfS obsesses over the marginal gains of shifting from 3 to 2 HESA collections, these institutions are concurrently delivering 14 Individualised Learner Record (ILR) returns to the ESFA. They are also making termly student attendance returns to the SLC. Each of these collections means running separate data processes and systems, uploading to a myriad of different data portals, running through different approaches to data checking, sign-off and audit. The unnecessary cost that this duplication in data collection gears into the system is eye-watering; it eclipses any wins that may emerge from the current OfS review.

The boundaries between FE and HE have always been a messy place in terms of funding and regulation and the picture is likely to become even more complex with the development of a Lifelong Learning Loan Entitlement. As David Kernohan recently pointed out, the plumbing necessary to support LLE looks a lot more like the current FE data infrastructure than the HE equivalent.

Back to basics

The fundamental problem is that OfS appears unwilling – or maybe unable – to engage with the other data collectors in this space and come up with an approach to data interactions that rationalises this mess into something that delivers the sort of burden reduction and increase in utility that we would all like to see. Paragraphs 40 and 41 of the OfS consultation acknowledge the mess around the HE/FE border and basically say “we’re not budging, and neither are they.”

This siloed approach to data is rooted deep in history. The boundaries of these data silos go back to the 1992 Act and the creation of the English HE sector as we know it. Although it was widely described as the removal of the binary divide between polytechnics and universities, the reality is that the 1992 changes simply moved the binary line to its new position between HE and FE. Separate – and very different – arrangements were put in place for the funding and regulation of these sectors, including different arrangements for data collection and the monitoring and assurance of academic quality and standards. These issues have been baked into the system over three decades.

Time for a bigger question?

Of course, the other big change that has happened during these 65 weeks is that Michelle Donelan is no longer Minister for Universities. In September 2021 her role was expanded to Minister of State for Further and Higher Education, bringing with it the explicit recognition that the development and implementation of policy across FE and HE needs to be more coherent in order to meet the needs of students, businesses and the wider economy and society.

Maybe it is time for the minister to revisit the question of data burden, not with an eye to Data Futures, but thinking more broadly about the future data that will be needed to support the funding and regulation of further and higher education in England.

The current duplication in data collections is a colossal and unnecessary drain on resources.

3 responses to “The OfS Data Futures consultation: right answer, wrong question

  1. Good article, raising an important issue which needs to be addressed. The wider question is whether it still will make sense to have separate regulatory arrangements for FE and HE when the LLE comes in, and whether the path being taken in Wales, following Scotland, of a single post-16 regulator would be the most sensible course of action in England.

  2. And, of course, on top of HESA, ESFA, and SLC, there is also Health Education England,
    and all the other regulatory bodies, who were promised Data Futures would meet their in-year data needs.

  3. Very interesting and applicable here in Australia after a transition to near time reporting under TCSI, VET(FE) Data Streamlining intends to add additional burden to vendors and institutions alike, where a partnership and common approach would make better sense.

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