What’s odd about the latest award of degree awarding powers
David Kernohan is Deputy Editor of Wonkhe
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On the first day of the new year, Warwickshire College saw an Order granting full taught degree awarding powers come into force,
It had held time-limited powers without incident since 2014, extended initially for one year in 2020, and then for a further three – adding Batchelor’s degrees to the initial foundation degree awarding powers – in 2021.
As of 2022-23 it had more than 330 students studying for a first degree, plus another 140 studying foundation degree or other sub-degree higher education courses. It holds a Bronze TEF award. It does not have, and never has had, a specific condition of registration. To the best of our public knowledge it has never been investigated by the OfS in terms of quality or standards.
In higher education terms it is a success story – benefitting from the now-legendary “level playing field” and its own meritorious conduct to offer its own awards in competition with England’s most prestigious universities. Having initially been approved for time limited degree awarding powers by an Order of the Privy Council, it has been tested and found competent by several iterations of regulatory systems.
And yet. The back end of last year saw the publication of the Power to Award Degrees etc. (Warwickshire College) Order of Council 2014 (Amendment) Order 2024, which specifically forbids the college from validating provision elsewhere.
Warwickshire College shall not authorise other institutions to grant such awards as specified in article 2 of this Order on its behalf. Warwickshire College shall only grant the awards specified in article 2 to persons enrolled with it at the time they complete the course of study for which the award is granted.
This is emphatically not because of a previously identified issue with such conduct – Warwickshire never has and does not currently validate awards delivered elsewhere. I am told that the Office for Students is aware that this is the case, but what I’m not able to get out of them is why this condition has been imposed.
Looking back over recent awards of full tDAPs, there doesn’t seem to be any consistency in the way these conditions are applied. For example, when the University of Law got indefinite tDAPs in 2024, there were no stipulations about franchise or partnership activity. Neither were there such stipulations when Regent’s University London got indefinite tDAPs. Luminate Education got authority to award degrees on a time-limited basis, alongside the conversion of foundation degree awarding powers to indefinite status – it is specifically (section 5) permitted to see other providers grant awards on its behalf.
There’s been no OfS DAPs assessment report relating to Warwickshire that sheds any light on the issue. Astute readers may also note that OfS has said it will not be processing DAPs applications in the future, so we are unlikely to get any further comparators.
To the best of my knowledge, Warwickshire College is unique in having indefinite DAPs and being forbidden to have awards made to students that do not study at the college. And it is impossible to say why.
Edit: I have been led to understand that other than providers with New DAPs (where restrictions around validation and sub contracting are applied to all) authorisation restrictions are applied to providers granted Full DAPs on a case by case basis, linked to a provider’s individual assessment for its powers. Quite what Warwickshire is meant to have done to trigger this remains unclear.
I doubt this anything to do with Warwickshire College, but more to do with the changing landscape of HE and increased focus on risky partnership activity.
If you look at some of the recent providers who have raised concerns about loan fraud, in some cases they have been validated or offer franchised provision from those with recent DAP awards.
This activity is risky and those with recent DAP awards are unlikely to have the experience and scale to manage the risk sufficiently.
I suspect we’ll see more of this type of restriction in the future.
While I understand concerns regarding franchising/validated arrangements generally, It is concerning that new entrants to the Degree Awarding Sector are being treated differently to those already established. It is clearly not the ‘level playing field’ we were promised over 10 years ago.
OfS should deal with the problem rather than restrict new entrants for an activity that there is no evidence that they were at risk of engaging in.