If you believe – as many do – that English higher education is among the best in the world, it can come as an unwelcome surprise to learn that in many ways it is not.
As a nation that likes to promote the idea that our universities are globally excellent, it feels very odd to realise that the rest of the world is doing things rather better when it comes to quality assurance.
And what’s particularly alarming about this is that the new state of the art is based on the systems and processes set up in England around two decades ago.
Further afield
The main bone of contention between OfS and the rest of the quality assurance world – and the reason why England is coloured in yellow rather than green on the infamous EQAR map – and the reason why QAA had to demit from England’s statutory Designated Quality Body role – is that the European Standards and Guidance (ESG) require a cyclical review of institutional quality processes and involve the opinions of students, while OfS wants things to be more vibes risk-based and feels quality assurance is far too important to get actual students involved.
Harsh? Perhaps. In the design of its regulatory framework the OfS was aiming to reduce burden by focusing mainly on where there were clear issues with quality – with the enhancement end handled by the TEF and the student aspect handled by actual data on how they get on academically (the B3 measures of continuation, completion, and progression) and more generally (the National Student Survey). It has even been argued (unsuccessfully) in the past that as TEF is kind of cyclical if you squint a bit, and it does sort of involve students, that England is in fact ESG compliant.
It’s not like OfS were deliberately setting out to ignore international norms, it was more that it was trying to address English HE’s historic dislike for lengthy external reviews of quality as it established a radically new system of regulation – and cyclical reviews with detailed requirements on student involvement were getting in the way of this. Obviously this was completely successful, as now nobody complains about regulatory burden and there are no concerns about the quality of education in any part of English higher education among students or other stakeholders.
Those ESG international standards were first published in 2005,with the (most recent) 2015 revision adopted by ministers from 47 countries (including the UK). There is a revision underway led by the E4 group: the European Association for Quality Assurance in Higher Education (ENQA), ESU, EUA and EURASHE – fascinatingly, the directors of three out of four of these organisations are British. The ESG are the agreed official standards for higher education quality assurance within the Bologna process (remember that?) but are also influential further afield (as a reference point for similar standards in Africa, South East Asia, and Latin America. The pandemic knocked the process off kilter a bit, but a new ESG is coming in 2027, with a final text likely to be available in 2026.
A lot of the work has already been done, not least via the ENQA-led and EU-funded QA-FIT project. The final report, from 2024, set out key considerations for a new ESG – it’s very much going to be a minor review of the standards themselves, but there is some interesting thinking about flexibility in quality assurance methodologies.
The UK is not England
International standards are reflected more clearly in other parts of the UK.
Britain’s newest higher education regulator, Medr, continues to base higher education quality assurance on independent cyclical reviews involving peer review and student input, which reads across to widely accepted international standards (such as the ESG). Every registered provider will be assessed at least every five years, and new entrants will be assessed on entry. This sits alongside a parallel focus on teaching enhancement and a focus on student needs and student outcomes – plus a programme of triennial visits and annual returns to examine the state of provider governance.
Over at the Scottish Funding Council the Tertiary Quality Enhancement Framework (TQEF) builds on the success of the enhancement themes that have underpinned Scottish higher education quality for the past 20 years. The TQEF again involves ESG-compliant cyclical independent review alongside annual quality assurance engagements with the regulator and an intelligent use of data. As in Wales, there are links across to the assessment of the quality of governance – but what sets TQEF apart is the continued focus on enhancement, looking not just for evidence of quality but evidence of a culture of improvement.
Teaching quality and governance are also currently assessed by cyclical engagements in Northern Ireland. The (primarily desk-based) Annual Performance Review draws on existing data and peer review, alongside a governance return and engagement throughout the year, to give a single rating to each provider in the system. Where there are serious concerns an independent investigation (including a visit) is put in place. A consultation process to develop a new quality model for Northern Ireland is underway – the current approach simply continues the 2016 HEFCE approach (which was, ironically, originally hoped to cover England, Wales, and Northern Ireland while aligning to ESG).
The case of TNE
You could see this as a dull, doctrinal, dispute of the sort that higher education is riven with – you could, indeed, respond in the traditional way that English universities do in these kinds of discussions by putting your fingers in your ears and repeating the word “autonomy” in a silly voice. But the ESG is a big deal: it is near essential to demonstrate compliance if you want to get stuck into any transnational education or set up an international academic partnership.
As more parts of the world are now demanding access to high quality higher education, it seems fair to assume that much of this will be delivered – in the country or online – by providers elsewhere. In England, we still have no meaningful way of assuring the quality of transnational education (something that we appear to be among the best in the world at expanding)? Indeed, we can’t even collect individualised student data about TNE.
Almost by definition, regulation of TNE requires international cooperation and international knowledge – the quasi-colonial idea that if the originating university is in good standing then everything it does overseas is going to be fine is simply not an option. National systems of quality need to be receptive to collaboration and co-regulation as more and more cross-border provision is developed, in terms of rigor, comparability (to avoid unnecessary burden) and flexibility to meet local needs and concerns.
Of course, concerns about the quality of transnational education are not unique to England. ENQA has been discussing the issue as a part of conversations around ESG – and there are plans to develop an international framework, with a specific project to develop this already underway (which involves our very own QAA). Beyond Europe, the International Network for Quality Assurance Agencies in Higher Education (INQAAHE – readers may recall that at great expense OfS is an associated member, and that the current chair is none other than the QAA’s Vicki Stott) works in partnership with UNESCO on cross-border provision.
And it will be well worth keeping an eye on the forthcoming UNESCO second intergovernmental conference of state parties to the Global Convention on Higher Education later this month in Paris, which looks set to adopt provisions and guidance on TNE with a mind to developing a draft subsidiary text for adoptions. The UK government ratified the original convention, which at heart deals with the global recognition of qualifications, in 2022. That seems to be the limit of UK involvement – there’s been no signs that the UK government will even attend this meeting.
TNE, of course, is just one example. There’s ongoing work about credit transfer, microcredentials, online learning, and all the other stuff that is on the English to-do pile. They’re all global problems and they will all need global (or at the very least, cross system) solutions.
Plucky little England going it alone
The mood music at OfS – as per some questions to Susan Lapworth at a recent conference – is that the quality regime is “nicely up and running”, with the various arms of activity (threshold assessment for degree awarding powers, registration, and university titles; the B conditions and associated investigations; and the Teaching Excellence Framework) finally and smoothly “coming together”.
A blog post earlier this month from Head of Student Outcomes Graeme Rosenberg outlined more general thinking about bringing these strands into better alignment, while taking the opportunity to fix a few glaring issues (yes, our system of quality assurance probably should cover taught postgraduate provision – yes, we might need to think about actually visiting providers a bit more as the B3 investigations have demonstrated). On the inclusion of transnational education within this system, the regulator has “heard reservations” – which does not sound like the issue will be top of the list of priorities.
To be clear, any movement at all on quality assurance is encouraging – the Industry and Regulators Committee report was scathing on the then-current state of affairs, and even though the Behan review solidified the sense that OfS would do this work itself it was not at all happy with the current fragmentary, poorly understood, and internationally isolated system.
But this still keeps England a long way off the international pace. The ESG standards and the TNE guidance UNESCO eventually adopts won’t be perfect, but they will be the state of the art. And England – despite historic strengths – doesn’t even really have a seat at the table.
