SFC catches the conditions of registration bug

Regulation is contagious, it seems.

David Kernohan is Deputy Editor of Wonkhe

The Scottish Funding Council has announced details of a new Outcomes Framework and Assurance Model.

It will see a new articulation between institutional and national aims; allow for a clearer understanding of the benefits universities and colleges bring for staff, students, and wider society; and attempt to cut burden and duplication of effort that is inherent to monitoring and accountability process. It will take effect from the 2024-2025, a very swift change indeed, but one based on a great deal of prior work and consultation

Since 2012 the SFC’s principal means of regulation has been via outcomes agreements. This itself was an innovation – round about the same time England was convulsing over £9,000 fees and Scotland was definitely moving in the other direction it was decided that what the government is paying universities to do needed to be clarified.

Outcomes agreements were negotiated each academic year for each provider (HE and FE) that SFC has a relationship with – setting out what would be achieved for learners and society as a whole. This, broadly, has worked well – but there has been some concern that it is resource intensive, fails to articulate with wider sector or national goals, and doesn’t reflect all the other plans and responses expected of universities and colleges.

In reviewing basically the entirety of Scottish tertiary education, the “coherence and stability review” recommended that the whole thing should be clarified, both in terms of expectations placed on providers and on the way progress against these targets is monitored. And that, in a nutshell, is what today’s announcement does.

The big shift is in the way targets for outcomes and activity are set. In the old model, SFC got round the table with each provider to agree these for the forthcoming year. Providers will now have more autonomy to make strategic and operational plans focused on the future, with SFC instead focusing on what has been delivered in the previous year. Outcomes monitoring based on plans and targets was always a bit of a misnomer, as planning can only really capture aspirations and (to a degree) inputs. The new approach gives providers their own space to decide what to do, with SFC focusing on whether it turned out to be any good.

That said, it isn’t quite a free-for-all. There is an outcomes framework setting out what it is expected a “well-performing” university should be doing. This is what it looks like:

  • Funding regularity (SFC funding is used “for its intended purpose”)
  • Good governance (governing bodies comply with SFC and related requirements)
  • Financial viability and sustainability (credible longer term plans and 1-2 years of viability based on current plans))
  • Estates and infrastructure – (Estates are “well-managed” and support what the provider is trying to achieve)
  • High quality learning and teaching (pretty much what it says, couched in terms of student expectations)
  • Student interests, access, and success (student support)
  • Skills and work-based learning (students equipped to become “work-ready” graduates)
  • Research excellence
  • Knowledge exchange and innovation

The latter two apply to universities and not colleges, but all providers also have responsibilities under two cross-cutting themes of net zero and EDI.

Monitoring will be data driven, supported by thematic reviews and the providers own contextual commentary. If a provider isn’t delivering on these expected outcomes within its own context, SFC has a menu of options: funding recovery or adjustment, condition of grant, action plan requirements, referral for investigation or intervention, investigation.

Is this sounding like (English and Welsh style) conditions of registration to you too? It certainly feels like Scotland is now closer to the UK regulatory trend.

If you are reading this in a provider in Scotland, you’ll need to know that the deadline for the final old-style OA evaluation reports and case studies is 2 December this year, with the year after seeing a contextual commentary and case studies due on 28 November 2025.

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