London Churchill College gets a condition of registration over quality

London Churchill College is the latest English provider of higher education to have a specific ongoing condition of registration placed upon it by the Office for Students - and OfS has published a “regulatory case report” to explain.

David Kernohan is Acting Editor of Wonkhe

We’ve heard lots about OfS’ quantitative condition for quality (B3) in recent weeks – but this concerns qualitative assessment. The new condition (BA) covers risks relevant to condition B1 (“well designed courses”), B2 (“student support”), and B4 (“qualification standards”).

Rather than seeking specific improvements from Churchill, it instructs the college to undergo an assessment by the QAA (the Designated Quality Body, in England) to ensure it is addressing the concerns raised in a previous QAA Quality and Standards Review (QSR) – in September 2019!

Why has it taken the Office for Students three years to act on this report?

You’ll look in vain for a 2019 report from the QAA about Churchill from that year on the website – though you can find a rich tapestry of previous reports and interventions. For instance:

  • In 2016 a Higher Education Review found that education at the college did not meet the standards expected of higher education in England. It cited fairly broad issues with recruitment, internal quality review, and oversight of work placements. It required progress against an action plan developed by the college, a follow up review in 2017 found some progress, noting that some policies were yet to be implemented, but the college was eventually found to “meet expectations”.
  • Also in 2017 the Student Loans Company raised concerns about academic malpractice. This followed a television programme (“3GBoss”) in which members of the public competed to enrol students to the college. The college had also “recently removed its name and logo from a site offering to write assignment for its students”. QAA required the provider to produce an action plan to address concerns over academic malpractice and assessment policies.
  • In 2018 – Fairly fundamental concerns about the quality of a pair of 2016-17 foundation degrees which saw no students progress to year two. The college was asked to prepare a detailed action plan addressing most areas in preparing, recruiting to, running, assessing, and closing a programme – and to consider “whether any form of redress” should be offered.

All in all it is a record of interventions that suggests that care and concern should be taken by regulators in managing risks associated with provision at Churchill.

In excerpts from the 2019 QAA Quality and Standards Review the Office for Students notes serious concerns about:

  • Support for students on work experience placements (an issue noted in 2016 review)
  • Attendance monitoring (an issue raised in 2016)
  • Academic standards as relates to external partners (issues raised in 2016)

As of today London Churchill College holds an “Approved” status, allowing access to fee loans up to the basic rate and student support. The 2019 date on the QSR report suggests that the application to join the register came before that time – OfS does (although not infallibly) ask the Designated Quality Body to review the quality of provision of applicants at the point of application.

The September 2019 date also means that the report would have been completed, and passed to the OfS by the QAA most likely by the end of 2019. The report has not yet been published because it is the OfS, not the QAA, that decides when and in what form these reports are published.

One of the concerns raised by the QAA:

The college does not always produce definitive data on student attendance or plans to ensure that students are suitably supported.”

…reads very much like a clear breach of registration condition B2. There clearly are mitigating factors (the OfS statement mentions that the college has plans in place) and in the interests of transparency, I feel like we should know more about what has been done to assuage these concerns.

Though smaller providers can change in ethos and leadership style very quickly, a cursory look at previous interactions with the QAA suggests Churchill has produced many action plans previously – and it is to be hoped that the success (or otherwise) of these historic plans have been taken into account. Either way, it would be good to know.

The QAA will reassess the college against the conditions and its action plan, at a time and date to be determined by the OfS. Meanwhile, Churchill can access fee loans, and can recruit students based on the expectation they can access maintenance loans.

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