The sector needs clarity over mandatory subscriptions

Implementing regulatory reform brings with it a host of consultations, which in spite of our best efforts, can add to a sense of fatigue.

There’s a lot on at the moment. The swirl of competing policy agendas is taking up significant bandwidth and – as the Wonkhe 360 survey shows us – giving university and college staff a lot to take in.

Unexpected bills

We’ve reviewed the feedback to consultation on the fees we will charge for work as the Designated Quality Body (DQB) in England, including charges applied to all providers for the DQB infrastructure and fees for specific institutions that need a Quality and Standards Review or a degree awarding powers assessment. The clearest message that I’ve taken from the consultation is there is still real confusion about what fees, both to QAA and to different agencies, will cover.

It’s tricky for me to address this in full here. The finances associated with being a regulated institution encompass payments to a number of organisations. Not just QAA, but also the Office for Students, and HESA. There will be internal costs to consider: staff time, and in some cases, reshaping internal systems so that they meet the requirements of the framework.

Key questions

So what did universities and colleges raise with us? The biggest takeaway was that people wanted clarity on not just how much we will be charging, but exactly what that payment will fund. In some cases there is, I think, an assumption that some things will continue as they were in spite of the wide ranging regulatory reform.

In particular, some queried if we would be double charging. This was either because they’ve already paid for their QAA subscription (assuming wrongly that these funded reviews work under the old, funding council-led system). Some of the decisions had already been made for us, written on vellum. The Higher Education and Research Act 2017 is very clear on what assessment functions QAA will carry out as the designated body and, in turn, for which we can charge through these fees. This isn’t double charging for previous work, but funding a brand new regulatory system.

There were also queries about why the DQB fee doesn’t cover things like Quality Code advice and guidance, or our subject benchmark statements. The legislation in England doesn’t allow this and so our sector-focussed work (in England) will in future be paid for through our new membership scheme. Northern Ireland, Scotland and Wales remain as is.

We’ve subjected ourselves to rigorous independent scrutiny, and I’m confident that our calculations and funding mechanisms are robust, accurate and fair. We worked closely with the Office for Students in a working group comprising representatives of the sector in England, and with independent input from economic consultants. Every year we will ask our financial auditors to verify that these funds are only used for designated quality body purposes.

Flat or banded?

We were grateful for specific feedback on the fees themselves. Responses did show the nation was equally divided with strong views on each side, although the final voting percentages were more akin to the Scottish independence referendum than Brexit.

There was very mixed feedback as to whether we should charge a flat fee, as the infrastructure requirements for QAA are not necessarily affected by provider size, or a banded model that would better reflect affordability. Some argued we should charge the same amount per student across all providers and another a hybrid of both.

The responses ultimately favoured banding, with 68% of respondents agreeing that this is a credible way to calculate fees. However, some queried whether our proposed banded fees model took account of the government policy objectives to make it more accessible for new higher education providers to enter the system.

We’ve listened to these arguments, and have amended our banding model by introducing a new band for the very largest institutions. During the process of the consultation QAA has also identified efficiencies and adjusted fee levels accordingly. We are also adapting our organisation so that we can deliver our respective roles free of conflict of interest.

We’ve worked hard to set a new benchmark of transparency and have taken on board the feedback from a diverse range of universities and colleges. Alongside our designated body fees work, we’re seeking feedback on a new membership proposition that will offer QAA services of value to the sector. At the request of many in attendance at our annual conference earlier this month, we have extended the deadline for QAA members to respond to a survey to Friday 24 May

Membership services will, I believe, offer choice on much needed enhancement and collaborative work beyond the regulatory threshold and ensure at their core that the sector In England, through QAA, preserves its role in the system of shared responsibility for establishing and maintaining the frameworks for quality and standards across the UK

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