New lengthier OfS registration process
David Kernohan is Deputy Editor of Wonkhe
Way back in 2020 (just pre-lockdown, in fact) Wonkhe carried an article by Adam Campbell from the London Studio Centre about how much hard work it is to get registered with the Office for Students as a new provider. It’s a theme that resonated with many – a part of the reason for establishing OfS was to make entry into the sector more straightforward, and – on the ground – it didn’t feel like that.
To be clear, having everyone delivering higher education registered (in some way) with the OfS is a really good idea. It offers regulatory oversight, and brings protections for both students and public funds that are sorely needed. When people talk (as often happens) about the dangers in some franchise and partnership arrangements, these are dangers that could be minimised if OfS had direct regulatory oversight of the place doing the teaching.
OfS, for its part, did acknowledge that the process was onerous and had issues – before proceeding to blame the then-designated quality body (DQB), the Quality Assurance Agency (QAA) for doing things slowly. The messy and protracted divorce between OfS and QAA didn’t really do anyone any favours, but it at least removed the grist that OfS saw in this particular mill.
Today, OfS released new guidance for providers looking to register (a third update to the venerable Regulatory Advice 3: Registration of English higher education providers with the OfS). In the main the changes are pretty unremarkable. There’s the expected Stalin-esque removal of all mentions of the DQB (they miss two – if you get bored over Christmas comment below with the paragraph numbers), and there’s all the new stuff around the “standards” initial registration condition (B8).
B8 is pretty much as you might expect – OfS ask for a whole pile of programme documentation (a sample from an initial declaration of everything you possess that may be relevant) which is read through by three of the new “academic assessors”. There’s a draft report for you to complain about, before the regulator thinks about publishing the final version.
There’s a sneaky bit of added burden in B7 (Quality) too – the previous iteration (May 2022) generally asked for a representative sample of (draft or final) course and module documents, “or” details of the course approval process and timings. In December 2023, this “or” has become “and” throughout.
But my favourite bit has to be the timings.
In the last iteration there was a four week pause for checking the completeness of the application, followed by an 8-12 week assessment of preliminary conditions. Then the DQB would go off and do a standards assessment (8 weeks) while OfS simultaneously performed a quality assessment (12-16 weeks). Four weeks from the later of those two and you’d have a decision – so 36 weeks in total at most.
Because OfS now also does the standards assessment there has been a change – the early checking (4 weeks) and preliminary assessment (8-12 weeks) remain the same, but a new combined quality and standards assessment from OfS now takes an astonishing 25-30 weeks. Add the 4 week decision time at the end, and the process as a whole blossoms to 50 weeks – effectively a full academic year!
This lengthened enhanced assessment cost you £28.463 (up from an average of about £15k under the old system) so – merry Christmas, I guess.
The £28k for the quality stuff seems to be substantially more than the fees the QAA were charging for the same work, which started at around £15k. So much for the claims from the OfS that it would be cheaper for them to do it themselves.
All of the QAA’s fee information can still be found online on the DQB website and if I’m reading it right their true costs came in lower so they refunded money, meaning only their most expensive and longest review would be more money than what OfS will charge.
Oh well there’s some nice evidence for the latest review of the OfS to ponder.