Whatever happened to student protection?

Although securing the finances of some universities won’t change the fact that a decent wedge of students won’t be able to meaningfully take advantage of what’s left that’s on offer unless something is done to shore up their finances too.

And as I’ve argued before, raw admissions and drop-out stats are not a good way of measuring that.

But more broadly, what I’ve found especially interesting about the “discourse” this week has been about risk – and who bears it.

In 2014 a third of students in the HEPI/Advance HE Student Academic Experience Survey responded negatively to the question of whether they would have chosen a different course knowing what they know now.

This year, when asked if they would choose the same course at the same institution, just 6 in 10 said yes.

That was, lest we forget, when the state in England was only expecting about 50p in the pound back for the loans it made on undergraduate tuition and maintenance.

The point is that signing up to the conveyor belt of higher education and its near-lifetime of “debt” payments involves a level of risk – and the government didn’t want to take on any more of the risk of failure itself.

Instead, and in summary, the government’s 5-pronged plan to mitigate those risks for students might be summarised as follows:

The first was financial – if your course doesn’t lead to a whopping salary you’ll have a decent chunk of your debt written off.

But the last government chose to remove a large amount of that protection by reducing the threshold over which graduates start to pay back, and extending the loan term to 40 years.

The second was that sufficient information – mainly about past performance – would mean students chose the right course and university for them.

But many of those metrics are either meaningless at the whole provider level, or now meaningless at subject level because students have no idea whether their course will operate in anything like the way it has in the past – or even if the staff they met on their open day even still work there.

The third was to make providers have a Student Protection Plans that was supposed to ensure the course and provider didn’t stop operating. That regime has proved to be useless at spotting implosions (course still runs but isn’t really the same course) and explosions (SPPs don’t work if lots of providers are in trouble all at once).

The fourth was a strengthening of compliance with consumer protection law – summarised as “you’ll get what we promised”. But the right is almost impossible to enforce, and promised progress in this area from OfS is conspicuous by its abscence.

The fifth was transfer – it was supposed to be very easy to transfer university. Pretty much nobody cares about that, and OfS stopped even doing data on it ages ago.

If all five of those key protections are pretty much in the bin, while the contribution from students/graduates has increased significantly, I can see no reason at all why we shouldn’t reveal to prospective students which universities are “on the brink”.

Maybe some are under specific conditions because they are at increased risk of, or are in actual breach of, the “D” conditions. But we likely wouldn’t be told because of the “run on the bank” thing.

Yes, telling us would make that provider more precarious. But it is not the job of applicants to take on that risk. It is not on them to shoulder that gamble. That is simply not fair. It’s what taxes are for.

Ironically, of course, in those Student Protection Plans providers are supposed to reveal how precarious a university’s financial position is.

Under OfS’ own guidance, universities are supposed to be transparent for applicants and students about the risks that are reasonably likely to occur and the measures a university will put in place if any of these risks do crystallise.

In theory OfS considers what information an applicant might “reasonably expect to have” to make an “informed choice about study” and universities are supposed to consider their approach to their SPP from the same perspective.

I don’t think I need a poll in the field to demonstrate that applicants would “reasonably expect” to know if their chosen provider was close to going under – even more so if its old and out of date SPP (as the majority still are) is still saying that the finances are great and the risks to continuation of study infinitesimally small.

Back in the day, the Department for Education (DfE) said that if there were wider economic changes that dramatically affected the sustainability of many providers, OfS would review its regulation of individual providers, with “particular regard” to student protection:

In order to retain the same level of protection for students, OfS would work with providers to improve their student protection plans so that they remain strong, deliverable, and in service of the student interest.

I do wonder how much more drama OfS is looking for.

Even if you take the view – as Bridget Phillipson apparently does – that there is an expectation that universities should “manage their budgets” as independent and autonomous institutions, the role of the state is surely to protect those who are funding them.