As OfS consults on a TEF that punishes rather than rewards, Jim Dickinson imagines a year as an SU officer at a struggling provider and finds honesty the worst policy

The first thing you notice is the name.
The “Office for Students” sounds like it’s on your side – a sort of ombudsman, or a union’s big sibling, or a thing you can go to for help.
You’re three weeks into the job as an SU officer. You’d stood in the spring mainly because the inter-campus bus had been cut, half of your final year options had been scrapped, and the “seminar” groups for what was left had swollen to 40 people by the end of your course.
Thank god most students couldn’t afford to turn up.
In your first meeting with university managers yesterday, someone mentioned a “sustainability programme” that sounded like a plan to push those class sizes higher still. On the walk back across campus your rep coordinator, who’s on the minimum wage and looking for another job, said everyone knows sustainability means sackings – and sackings mean things only get worse.
Nobody in your family had been to university before you. Your mum still tells the neighbours you’re “the president”, and when something doesn’t make sense your first instinct, learned in three years of seminars where everyone else seemed to know the rules, is that the problem is you.
Your induction checklist says to read up on something called OfS and something called TEF. The website tells you the first is a regulator and the second improves universities, which sounds like exactly what you need.
In the back of your notebook you start a list headed “Making things better, questions for OfS”, and write down the first one – “Who do I email?” The plan is to send them once you’ve got five or six, and you’re sure someone there will write back with answers, because you’re an optimist, and that’s how you got elected.
An email arrives. There’s a chance to represent the university nationally by providing “authentic student voice”. It feels like a big thing for about an hour, until you read it properly and work out that the regulator is coming to collect evidence, and you’re an informant.
The previous week, the university had confirmed that the SU’s block grant is to be cut. In the university’s budget it’s a rounding error, but for you it’s the hours of the one staff member who knows how to run a survey. Your union manager tells you the finance director said the SU “needed to set an example”. Nobody said to whom.
TEF is optional now, you read – a university can take the “minimum requirements” route instead, pay a fee for its assessment and skip the ratings. But a tuition fee rise only comes through a TEF rating, and the university’s financial plan depends on it, so nobody in senior management debated whether to apply, only whether you’ll help get them over the line, pushing your members deeper into debt while you’re at it.
Universities applying for ratings are assessed for free, while smaller places without enough data to be rated pay for theirs, and nobody can tell you whether Bronze is even enough to get the fee rise, because that’s a government decision still being made somewhere else.
So the smallest providers pay, the prize hasn’t been decided, and the whole thing is optional for everyone except those who need the money. You assume you’ve missed something.
The guidance wants a “student submission” that will reflect the views of the wider student body, explain how its evidence was gathered and set out its limits. It comes with a template that poses a question for each of six criteria and offers examples of “stronger and weaker evidence”.
You get ten pages, and OfS supplies the template and some webinars. Everything else – the money, the data, the time – comes from the university, which must support you “without influencing” you. So the institution you’re meant to judge is paying for the judging, a fortnight after cutting your grant.
The university has taken on consultants to craft its own thirty pages, and you later read that the 2023 evaluation found paying consultants was one of the things that made for a strong submission.
You have a shared Google Doc, a student intern on eight hours a week, and a group chat that dies at nine because your vice president works nights at a supermarket.
You add a second question to the list – “Who pays for our side?”, and tell yourself there must be a fund you haven’t found yet.
Then you read what the ratings do. A university rated “Requires improvement” has to cut its intake by ten per cent, then by another ten per cent the following year, and in what used to be the SU bar you work it through on the back of an envelope – ninety per cent, eighty-one, seventy-three.
Fewer students means less fee income, and less income means more cuts, landing on courses that are already stretched and on the students you represent.
You read the section three times, sure you’ve misunderstood, but you haven’t. The response to poor teaching is to take money away from the teaching, and the people who pay are the students already here, whose only mistake was to enrol.
At the weekend you try explaining it to your mum, who has never read a consultation in her life. She listens to the bit about the ten per cent, frowns, and asks whether that means a university that’s struggling gets less money to get better with. You say yes, and wait for her to spot the clever part you’ve missed, but she just says “that’s daft, love” and puts the kettle on.
On the train back you write her question on the list word for word – “How does a university get better with less money?”, and feel better, because it’s the kind of question someone at OfS must already have answered.
Get Requires improvement twice in a row and it’s a breach of registration conditions, then escalation and possibly deregistration – a university closed by being starved slowly rather than by going suddenly bust.
You look for what protects students while that happens, and find that further education colleges got a special administration regime that puts learners first, while universities never did. The regulator can’t let a university fail safely, so it lets it shrink dangerously.
Your university is currently Bronze, which, you learn, means it meets the requirements. The conditions have been reworded from “high quality” to “satisfactory quality” so that Bronze can count as a pass, yet in a few years Bronze will also mean no growth, no new degree powers and maybe no fee rise.
It looks like a pass that gets punished like a fail, and you assume someone cleverer than you can explain why it isn’t.
Growth is a “risk to quality”, the document says, so you check whether that applies to Gold universities, which can grow as fast as they like with students sat on the floor being told they’re lucky to be there. They won’t be looked at again for five years – it only applies to universities like yours. To people like you.
Most of the judgements compare each university with a “benchmark”, meaning what similar universities with similar students achieve, and “in line with benchmark” counts as high quality.
So the average university is high quality by definition, and if everyone gets worse the benchmark sinks with them. At the back is a table showing full-time first degree continuation across the sector sliding from 91.1 to 88.0 per cent – fewer students getting through everywhere, in a system built not to notice.
There’s another way to the top. A university that gets ninety-five per cent of its students through can be rated outstanding whatever its benchmark, and you know which universities manage that, and how they pick their students.
There are floors too, but being below one while “broadly in line with benchmark” is normally fine. Your students’ backgrounds give your university a low benchmark, so the floor that protects everyone sits lower for them.
You know the ones who didn’t make it by name – the second year whose rent went up while her hours didn’t, the lad doing twenty-five hours a week in a warehouse, the carer whose mum got worse in November.
In the data each of them counts against the “teaching”, so your members’ poverty will be scored as the university’s failure, and you already know the response will be more cuts.
A university counts as consistently good if around eighty per cent of its students get a good experience, and you wonder whether the doubled seminar groups are the twenty per cent the rule exists to cover.
Half of the student experience judgement, you work out, rests on the National Student Survey, which you filled in as a finalist without anyone telling you what would be done with it. You’d never imagined it would be used like this.
The earnings measure leaves out graduates who are neither working nor studying, as if they’d never existed. Some of the data comes from students who started before the pandemic, so a rating that stays on course pages for five years will describe a university, and a staff, that no longer exist.
Someone in marketing mutters in a meeting that every course webpage will have to show the university’s overall rating. You ask how that helps when some courses are obviously better than others, and someone else from marketing laughs, as if you’re supposed to know why it doesn’t make sense.
The PVC explains that the regulator checks for newer data before handing out a Bronze but not before a Gold, because a Gold carries no “negative consequences” for the university – which is true, unless you’re an applicant who picked it who’s now sat on the floor applying for unpaid internships.
You’re flicking through the university’s TEF briefing slides when one of them jumps out. Closing courses, ending partnerships and restructuring, it says, can count as evidence that a university has responded to weak performance.
So the humanities department – merged with social sciences because applications have fallen, and the subject of a student petition – can go into the university’s submission as proof that it’s improving.
The London franchise partner is a different story. It’s coining it in, with numbers climbing every year and a slice of every fee flowing back to campus, so nobody is talking about closing it, even though its students now count fully in the university’s rating and its continuation figures are the worst in the whole operation.
You assume there must be a rule about what gets cut, and there is, sort of. A closure only looks suspicious if the university opens something similar afterwards. Otherwise any closure counts as getting better, whether it’s a course they can’t afford to run or, one day, a franchise that stops paying.
You think about the single mum you met on your day at the London Study Centre, who studies there two days a week because it’s on her bus route, and the humanities students on campus being taught out by whoever’s left. None of them chose any of this, and every one of them will be written up as progress.
You write “Where are they supposed to go?” on the list. That makes four, and you still haven’t emailed, but you tell yourself you need to understand it all better first.
Next you check who’s actually being assessed. The first round only covers undergraduates, with taught postgraduates joining “from the second cycle”, years away, because the data isn’t good enough and nobody has bothered to build them a survey.
Students on one-year courses can’t take the National Student Survey either, and the outcome measures only count UK-domiciled graduates.
At your university that leaves out the one-year master’s programmes full of international students, whose fees keep the undergraduate degrees going. They’re about a third of your members and your advisor’s busiest caseload, and they’re invisible to every part of the system until the 2030s.
Your vice president has spent all term lobbying for proper careers support for international students, and getting nowhere. Now you can see why nobody is worried – those graduates will never show up in the measures OfS uses.
The regulator is policing the degrees the university is cutting, and ignoring the ones that expanded to pay for them.
The independence rules looked like something on your side. The university can’t tell you what to write, suggest themes, discourage criticism or review your drafts, and its communications about the submission must be “neutral”.
But the rules only stop anyone pushing you, and nobody needs to, because you can do the maths. Tell the truth about life after the cuts and you might help bring about a Requires improvement rating, which brings a smaller intake, which brings more cuts to the courses your members are still on. The finance director doesn’t need to mention the block grant again. He already has.
Then there’s your own degree. The rating will sit on every course page in a standard logo for years, and you and every member you represent will graduate from whatever the university is rated. If it’s Requires improvement, your submission will have helped put that label next to the university’s name on the CV you’re about to send out – and your mum is still telling the neighbours you’re the president.
Opting out is no escape either. If you don’t submit you have to explain why, and your reasons can count against the university’s “student engagement”, while saying the university didn’t support you properly could put it in breach of a registration condition.
You draw a table in your notepad and work out that all the honest options hurt the university your members depend on, and the only one that doesn’t is something careful and balanced, where every criticism comes with a “however” and every problem with a vague “action plan in development”.
In the 2023 survey of student contacts, when the worst outcome was a Bronze, only about two thirds said it was definitely true they could say what they wanted, and a quarter said the process had damaged their relationship with the university – in a survey that wasn’t even anonymous. You wonder how it can be that the stakes have since got higher, yet nobody seems to have asked what that does to the evidence.
You start drafting anyway. You write a sentence about seminar groups doubling and delete it, write it again with “some students have reported” in front of it and “however, the university has been responsive” after it, and by midnight you have a paragraph so “balanced” that it no longer says anything. You hate it, and you can see exactly why the system would prefer it.
Before bed you add “What happens to us if I tell the truth?” to the list. It’s the first question you’re not sure you want answered.
The university has to send you its final submission so you can respond in yours, which someone in the office says makes you a rebuttal witness, publicly fact-checking your own university in front of its regulator.
Its version talks of a “strategic portfolio review” and a “sustainable, student-centred model”, and if you write an honest reply, everyone will know what those phrases really meant.
Your submission gets published, and before it is, the university has fourteen days to comment on “factual inaccuracies” and redactions – the same university that mustn’t review what you write.
Last time the judging was done by an independent panel of academics and students, which a review called essential. They might have understood. Now the regulator’s own staff vote on assessment teams, its staff chair the panels, and appeals go to another panel that its staff chair. It doesn’t feel fair, and you’re not sure who you’d complain to.
You go back to the thing you actually care about – what happens to the students already here if the rating is bad? There’s plenty for applicants, from logos on course pages to a “scorecard” user-tested on seventeen-year-olds.
But then you remember that the regulator’s own research says most applicants don’t use TEF, those who do use it to confirm decisions already made, they can’t tell Gold from Silver, and the source they trust most is the student submission you’re being squeezed into softening.
Even the timing fails them. Final ratings come out in January, after applicants have accepted offers based on the old rating, and the cut lands on the intake they’ve just joined. For students already enrolled at a university publicly judged inadequate there’s nothing – no duty to explain, no help to transfer, no special route to complain, and student protection only if their course actually closes.
A course rep you trained stops you outside the library to ask what a bad rating would mean for her degree, and whether she should think about transferring. You tell her you’ll find out. You don’t, because there’s nothing to find, and the next time you see her you take the long way round.
You write “What do I tell her?” on the list, and realise halfway through that nobody at OfS will ever be asked it, because nobody there will ever meet her.
You look for whoever is meant to help a university improve – an improvement team, some funding, the kind of support schools get – and there isn’t anyone. The fee rise that might have paid for improvement goes to universities that are already good, and being told you’re not good enough while losing resources is the only help on offer. You recognise the method, because it’s how your grant was cut.
You start writing “Who helps a university get better?” on the list and stop after three words, because you already know.
You look up where all this came from, assuming it must once have made sense. The minister who invented TEF said in 2015 that teaching had become a “poor cousin” to research and that great teachers deserved the careers and pay of great researchers. By 2017 he was citing a survey in which 81 per cent of universities had put extra money into teaching, almost half because of TEF.
You can see how that worked. In a growing sector with money, a reward for good teaching gave universities a reason to spend on it. Now the reward is withheld from those that can’t afford to spend, and the same rating also has to reassure applicants, police fraud, unlock fees and ration growth.
The same minister warned that student number controls would hurt the poorest students most. Yet here they are again, imposed by rating and falling on universities like yours. On people like you.
You think about the best lecturer you had, who stayed behind every week and answered emails on Sundays, and who is now on the redundancy list. The framework invented to reward people like her will now measure what her absence does to you.
Late one night you find the regulator’s own evaluation of the last TEF. It says the fee rise was a weak incentive, that the providers who got most out of the exercise were small, specialist and short of data and money, and that almost every provider that changed anything had acted on “educational gains” – what students actually learn and become.
The new system makes the fee rise the main lever, pushes small and specialist providers onto the route with no student submission and a fee to pay, and drops educational gains without a word. The consultation never mentions the evaluation, and you can’t find any plan to check whether the new system works.
“How will you know if any of this works?” is the last thing you write on the list. You never email. By then you’ve stopped believing anyone would reply, and if they did, you wouldn’t believe them.
By the spring you can see the choice you’ve been handed – tell the truth about what’s happening to your members’ education, or protect them from what the truth will cost.
You leave in June, before the provisional rating arrives in July, and if it’s bad, whoever has your job two years from now will write the next submission, with even more at stake, an even smaller grant and even fewer students left to represent.
You read the list back. None of the questions has an answer, yet between them they describe the system better than anything the regulator has published. All year you assumed the confusion was yours, the old first-in-family habit of thinking everyone else knows the rules. You hadn’t missed anything. You read it right every time, and it really is that stupid.
The first question, in July’s handwriting, was “Who do I email?” You know the answer now. Nobody.
You think about the name again – Office for Students. It’s true, technically – it’s for students in the abstract, for future students, for students as consumers, for students who go to open days, students as the reason it exists, students as a source of evidence. It just isn’t for these students, at this university, this year. It isn’t for you.
You went looking for help and found a regulator that needed you, gave you nothing, and had arranged things so that the only safe answer was the one that helped nobody.
On your last day you tear the list out of your notebook and leave it in a desk drawer for whoever gets elected next. You think about writing something hopeful at the top for them, but you’ve done enough lying for one year. So you add one final question to the list. “What’s the point?”

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