Elsewhere on the site Josh Freeman reflects on their “explosive” growth (up x 8 in a decade), their role in access (three in ten hold no qualifications, two thirds are mature), what they’re studying (there’s a lot of business studies) and the less than stellar completion rates of those on them.

But in many ways the problem with the report, and the Department for Education dataset that signalled similar things back in October, is all about the word “at”.

When the ad-hoc the DfE dataset appeared last year, effectively to justify the decision to “defund” (or at least reduce the tuition fees for) foundation years, my first alarm bell was the assertion that there were 105 English providers of foundation years in 2021/22, that 23 of these providers were based in London, and that 42 of the 105 providers had a low or unknown tariff in 2021/22 – similar findings to those in HEPI’s report.

I asked DfE to clarify what the word “at” meant – and it came back and confirmed that “at” meant the provider a student was registered at rather than taught at.

Given that pretty much all of the for-profit private providers (some of which are caught up in the NAO investigation) that I’ve been keeping an eye on that offer business degrees out of barely converted office blocks around the edges of London and other big cities, that made more sense.

The obvious hypothesis was that subcontracted out provision is where much of the growth has been, and there’s also a decent hypothesis that outcomes, characteristics, etc will also all differ depending on whether students are “taught and registered” or “registered and contracted out”.

The problem was what DfE said next.

When I asked why it hadn’t broken out subcontracted from taught, DfE asserted to me that “providers who subcontract their provision do so to local colleges”, and so “the region of the student wouldn’t differ”.

I did point out that a significant number of students registered with Canterbury Christ Church, Bucks New, Bath Spa, Suffolk, Leeds Trinity, Bedfordshire etc were almost certainly being taught at providers outside of the region, to pretty much no response.

DfE also said to me that the only outcomes metric which could be influenced by subcontracted provision is completion rate – suggesting that other outcomes measures “wouldn’t be that influenced” if their foundation year was subcontracted “since in most cases they would still undertake year 1 and the rest of their undergraduate studies with the registered provider”.

I did also point out that that was likely nonsense – the growth I’ve seen in the franchised-to for profits was in the whole degree, with a foundation year attached, being offered.

DfE stopped responding at that point.

The HEPI report appears to be similarly incurious – asserting (for example) that the East of England has 20 per cent of FY students without wondering whether Anglia Ruskin or Suffolk’s numbers might be franchising.

I see this happen a lot in HE policy – like when those who talk about international students seem unable to make any links to the student housing crisis we’ve seen. It’s like we put HE policy subjects in neat boxes and dare not mix them up.

It could be that a profit motive encourages private providers to aggressively recruit students on low or no quals, onto the cheapest to teach courses, and doesn’t worry too much about outcomes as long as the throughput volume is high. It could be – but we don’t know. And we do need to.

Because if it’s the case that franchised, for-profit franchising is dragging down the outcomes for disadvantaged students and causing fee reduction policy change that encourages others to pull out of it, the fee reduction will have represented a classic baby out with the bathwater moment. Now that really would be a “blind spot”.