A theory of change for the B3 bear

The OfS is thinking about why it does what it does to regulate based on outcomes

David Kernohan is Deputy Editor of Wonkhe

It feels like you can’t move for theories of change these days.

An understanding of why people do stuff that extends beyond “because we told them to” is behind most of the positive changes we’ve recently seen in the regulatory lifecourse of the Office for Students.

If you are in deep with OfS kremlinology, it represents a win for the John Blake faction. And this latest study, of the way that the B3 Bear of legend has manifested among senior managers around the sector, is of a piece with a worldview more likely to ask why than demand compliance.

This is a proper multi-stage job, with stage one’s telephone interviews at 40 providers leading to a series of in-depth interactions with just four at stage 2. There was no attempt to sample based on direct regulatory enforcement experience, but the pool included participation from every part of the sector – capturing the experience of registrars, heads of quality, and heads of data – and with a range of B3 data values.

The B3 conditions are the classic continuation, completion, and progression outcomes – used by the regulator as leading indicators to target more intensive regulatory actions: these ranging from letters through investigations to conditions of registration. The hope with this approach is that providers would adopt these indicators (and related leading information from stuff like learner analytics) as a means to drive quality assurance and enhancement: gratifyingly, this seems to be what has happened.I’ll offer one caveat – the majority of higher education providers look at a whole range of data in understanding learning and teaching quality (combined of course with the vestiges of the more systemic approach that is the legacy of the old cyclical external assurance methodology). And the report does note that:

A desire to improve and enhance performance and practice was stated as the primary motivation for actions in all four providers, not directly linked to revised B3

Respondents broadly understood B3 as being in compliance with institutional aims to provide students with a good higher education experience, though this was tempered by concerns about a homogenising effect and a lack of clarity around the way context was taken into account. All this needs to be seen through a lens of what might be termed mild mistrust around OfS’ regulatory aims.

What is used appears to be, on the whole, better data than OfS publishes. There is a lag in publishing at a sector level (notably last year and probably also next year), and providers understandably want a more up-to-date picture of what is going on. It is notable that people are using B3 terminology in speaking and thinking about real time data.

The provider level theory of change sadly, still seems to involve dragging course and module leaders in front of senior staff to “explain” deficiencies – reminding us all that these theories need to extend right the way down to the front line to be fully effective.

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