OfS consults on risk-based access

The OfS consultation on a risk based approach to access and participation is out now. David Kernohan gives you the context.

David Kernohan is Acting Editor of Wonkhe

An advanced preview of the direction of travel means few surprises in todays’ OfS access and participation plan consultation.

We already know that a new risk based approach will see the development of a national equality of opportunity risk register (EORR), against which providers will be asked to develop new 30 page four year plans (complete with quantifiable targets and an evaluative strategy).

The twist here is that providers get to choose from national and provider level risks based on their size, context, and mission – as well as the nature of the risks identified and on the actual or potential impact on prospective and current students. The one constant here is a “key sector level priority” on raising pre-16 attainment through engagement with schools,

It’s the nuts and bolts of this process – the format of the plans and associated summaries, and the ways in which the plans are to be assessed and monitored – that are primarily up for discussion here. Only proposal one deals with the basis of the process within an assessment of risk, and though respondees do get a chance to propose other approaches the suggestion that you quite like the plan you already have (that OfS has already approved) probably won’t cut the mustard.

The consultation closes on 10 November, the EORR launches in spring 2023 and the plans will kick off the following academic year.

At risk

The “risk” framing is interesting in the way it aligns with the current government tendency to discount structural issues in considering inequalities, while still retaining the focus on serially-disadvantaged groups (those more likely to be at risk of inequality, in the new argot).

Old-school PRINCE2/MSP practitioners may have perked up at the idea of what appears to be a participation risk register, but the usual calculus of likelihood and severity does not feature in either the provider template or the specimen EORR. This is curious as we are able to clearly define (from the OfS’ own data) the likelihood of someone from a particular group failing – for example – to continue in a course, and the severity could be expressed at the very least in terms of the likely financial loss over a lifetime as calculated by IFS with LEO data. We’ve not gone that far.

The actual definition of “risk” (from Annex E), is:

when an individual, because of circumstances that the individual did not choose, may have their choices about the nature and direction of their life reduced by the actions or inactions of another individual, organisation or system.

The political need to keep this focused on the individual rather than on groups – though there is a list of likely groups later on in the stated example, it is quite broad – again leaves some intriguing holes. It is possible to argue that certain courses (or, indeed, certain courses at certain providers) may offer some groups students less choices about their lives than others – reading across to the B3 dashboarding approach. Should providers, therefore, be discouraging groups that are less likely to get a benefit from a course from applying to that course?

And if we follow the logic right the way through – if all of the “risks” of a lack of opportunity are adequately addressed, then it follows that equality of outcomes has been achieved. Politically, what to OfS say if a particular risk is fully addressed but we still see inequalities (say by disability or ethnicity)? Who gets to break that to the galaxy brains of the Social Mobility Commission?

Blake’s six

The most useful reading in the document is the list of illustrative provider examples in Annex F – and not just because John Blake is unmasked as a fan of the Inbetweeners, Peep Show, The Archers, Capaldi-era Doctor Who, and the novels of Howard Jacobson and CS Lewis.

Here the expectations for what is very clearly a loosely sketched Oxbridge are set around a contribution to pre-16 attainment, better support through the section process, and a consideration of new approaches to challenges around Afro-Caribbean student success. A modern, vocational, university has a significant proportion of all students from military families – it is expected that it would lead the way nationally on efforts to ensure access and success for these students, while improving overall diversity by partnering with local schools.

An FE college would be raising schools attainment too, in order to reduce the numbers that need to resit English and maths GCSE, a specialist arts college may have an issue with white working class men from disadvantaged backgrounds, and disparities in outcomes – there a provider with 750 students would be “utilising its influence in the economy” to change practices.

The suggestion it improves outcomes overall by not being an art college isn’t there, but according to another example a larger pre-92 in a rural area may need to rethink its decision not to teach vocational skills as the only provider in the local area. And a post-92 example demonstrates it is possible to have a plan where no significant risks are identified – but it still has to report on work it is doing and consider how to improve even further.

I’m glad that OfS has not followed the logic of this approach right the way to the end. But it pushes right up against the idea that some providers (because of where they are based, who they recruit, and what they teach) are always going to struggle with aspects of access and participation work. Risks, after all, need to be examined in context – and though OfS does, to great credit, talk about context here it may find itself under significant ministerial pressure to make more instrumental interventions.

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