Friday 31 March 2023 is a landmark date for the English higher education sector.
It is the date that the Quality Assurance Agency (QAA) “demits” the role of England’s Designated Quality Body (DQB).
Since its establishment in 1997 QAA has been a cornerstone for the management of academic quality and standards in the sector, a role that now comes to an end in England. Though like the Roman Empire the end never seems to be quite the end – QAA still has contracts with the government to review overseas HEIs operating in England, who are not required to register with OfS.
As with the Roman Empire, with QAA you can chart the decline, but when was the fall?
The diminution of role for QAA when quality assurance was reset in 2011? HEFCE launching the Second Quality War when it started its review of quality assessment in 2015? The launch the following year of HEFCE’s still-born and unlamented Revised Operating Model for Quality Assessment? The relegation of QAA to bit-part player with the establishment of OfS in 2018, and the harrying of QAA in the subsequent years? The cutting out of QAA when OfS reviewed its quality and standards registration conditions in 2021 and 2022?
However you look at it though, March 2023 is clearly a significant point, as QAA steps back and OfS itself now becomes the DQB, albeit on a nominally “interim” basis.
Where we are left
Significant concerns have been expressed across the sector about QAA’s withdrawal from, and OfS’s assumption of, the DQB role. In January, the call from the four main higher education mission groups for an enquiry into OfS expressed these concerns about OfS taking on the DQB on a permanent basis. Of the 47 people who responded to the DfE consultation, 31 were opposed to the QAA formally losing the role of DQB.
Andrew Boggs has recently published a meticulous analysis about how where we are now in terms of the regulation of quality and standards undermines the intent of 2017’s Higher Education and Research Act. And the concerns that Paul Ashwin set out about the OfS, expertise and the legitimacy of regulation highlighted issues around the regulation of quality and standards.
Ashwin’s blog is particularly interesting as it in effect raises the question of the basis on which academic quality and standards are regulated, which in turn comes to the fundamental issue of where we locate the legitimacy of awards made by universities.
On one level the answer is obvious. The power to award degrees is defined by law and amounts to a protected status, one that has been reached through a number of routes in the past (royal charter, act of parliament etc.) and for which there is now a standard defined process.
But what’s the basis for decisions to grant degree awarding powers? The current process defines a single overriding criterion:
A self- critical, cohesive academic community with a proven commitment to the assurance of standards supported by effective quality systems.
Sometimes within the sector there has been (and perhaps still is) a tendency to focus on the second half of that criterion – the QA processes. But there’s a reason it’s the second half of the criterion. It only has any value if the first half is in place. The authority to award degree is fundamentally based in the nature, standing and commitment of the academic community awarding/seeking to award degrees.
The roots of autonomy
We sometimes overlook one of the distinctive qualities of universities. We design and approve the curriculum. We deliver and assess it, then make awards based on the learning demonstrated through that assessment. Yes, we sometimes choose to constrain our freedom in doing those things. We choose to deliver a qualifying medical degree and therefore accept a curriculum defined by the GMC. We decide to offer a degree apprenticeship, accepting the constraints and requirements of the apprenticeship standard. But none of this fundamentally changes the distinctiveness of universities: they are both autonomous awarding bodies, and they develop, deliver and assess the awards they make.
The authority to do this rests within the standing and status of our academic communities, with the result that what David Watson called the “commitment to systematic peer review” and “the ‘collaborative’ gene” has been at the heart of how we have assured quality and standards in UK higher education. This has progressed from self-regulation to co-regulation, but peer review and judgement have always been central to our approach. And they have always been fundamental to QAA’s approach.
Peer review hasn’t entirely disappeared with the supplanting of QAA by OfS. OfS has been keen to stress that TEF submissions are judged by a panel of peers, and their use of expert academic assessors in their ‘boots on the ground’ investigations. And of course suspected breaches of Registration Condition B5 (on standards) ‘will’ involve the DQB and by implication external, peer review.
The retreat of peer review
But then the erosion of the commitment to peer review starts to become apparent.
Suspected breaches of Conditions B1 (academic experience), B2 (resources, support and engagement) and B4 (assessment) “may” involve peer review. The previous guidance for applicants for admission to the OfS Register used to require a (peer) review undertaken by QAA as DQB; new guidance issued in October 2022 says that OfS “will determine whether it is necessary to undertake an assessment visit”.
Then there’s the report in the DfE memorandum for the post-legislative scrutiny of HERA of OfS’s view of the Framework for Higher Education Qualifications, developed by academic peers as part of a co-regulatory approach and re-titled by OfS as “sector-recognised standards”:
while this ensures the sector is adequately involved in setting standards, the OfS finds that this may constrain their ability to take a more direct regulatory approach in some circumstances
This is particularly interesting set alongside OfS’s attempts when consulting on its new B conditions to entice/incite universities to move away from the external examining system (clearly and forcibly resisted by the sector, thankfully).
I remember being at a QAA conference in 2014, just before HEFCE launched its review of quality assessment. Initially with great subtlety and urbanity, but with ever more directness, I listened to consecutive speeches by the Chief Executive, a Director and then a Deputy Director from QAA, telling us that if the sector didn’t make a stand then one of the things that we most valued in the approach to managing academic quality and standards, peer review, would be undermined and downgraded.
Those views were prescient.
We defend to the hilt the centrality of peer review and evaluation when we evaluate the quality of research – grant applications, article submissions, REF – with the fundamental decisions made by peers on the basis of their professional academic judgement. In England the sector has moved away from this in the way it manages academic quality and standards. Not entirely, but significantly.
And it is much the poorer for it.