Why are all the risks that students face being kept a secret?

There wasn’t much in there that was new for regular readers of Wonkhe, although there was a cracking quote from GBS CEO James Kennedy:

He describes courses that offer few options as “no-frills” and readily accepts the comparison with budget airlines or discount supermarkets. “Aldi’s a phenomenal business model,” he says. “It’s a very thoughtful and targeted model and we do the same. We organise ourselves around our students.”

The “new” thing in the piece is this nugget:

A similar assessment last year into GBS’s courses for Canterbury Christ Church University found it was “not consistently providing a high quality academic experience to students”, offered learning materials that were “not adequate” and used assessment methods that were not “valid, reliable or credible”, according to documents seen by the FT.

That’s interesting because while it has over the partnership with Oxford Brookes, OfS hasn’t announced any investigation into the CCCU and GBS tie up.

I asked OfS if it could give us any details about this assessment from “last year”, and got the usual no comment on something not published answer.

But that reminded me.

Back in October 2023, OfS announced the criteria for selecting providers for its 2024 round of “boots on the ground” B3 inspections.

It was, we were told, to specifically consider business and management courses and courses delivered through sub-contractual partnerships.

But since then, some 33 months ago, we’ve not heard a thing. We never heard whether those went ahead, we’ve not heard (if they did) what was found, we’ve not heard of any action that was taken, and we’ve not heard if any inspections were carried out in 2025 or 2026 – presumably not.

I asked OfS for any news on the above. Not even a reply this time.

Back in 2023, when it was endorsing OfS doing quality in-house instead of through the QAA, DfE said that as OfS is a risk-based regulator, that “enables them to act decisively where they will have the most impact on addressing poor quality provision.”

We’ve had three business plans since October 2023. In 2024 it pledged to “assess the student outcomes delivered by individual providers” and “take action where appropriate” – it expected to “publish the outcomes of our assessments of student outcomes” in the year.

In 2025 we got a commitment to “complete all quality assessments currently in progress”, and the line was repeated in the 2026 plan.

What we do know is that since 2022, franchised out students have gone from 92.5k to 160k in 2024/25, with further increases likely since when we look at HESES.

And in the partnerships data OfS put out last October, 132 partnerships (43 per cent of partnerships with reportable FT UG data) were below one of the B3 thresholds.

The FT piece has a quote from new joint CEOs Ruth Hannant and Polly Payne, who said they had “concerns about the risks some franchising activity poses to students” and that “we can and do take action” when standards fall short.

Really? How would we know? Leaks to the FT?

Maybe OfS has been busy on financial sustainability. Last week OfS published guidance setting out its financial viability and sustainability risk framework (HT to Andrew McGettigan), explaining how it assesses financial risk in practice, the characteristics and indicators that inform financial risk judgements for individual providers, and how it applies regulatory judgement concerning its published regulatory requirements in practice.

Last November, former CEO Susan Lapworth said that there were 24 providers in the 12-month risk-of-exit category – seven with more than 3,000 students and 17 smaller providers. She didn’t use the label “Category 4” in the select committee hearing, but the description corresponds to Category 4 in the published framework:

• acute financial challenges
• consistently negative operating cashflow relative to income, “demonstrating unviability”
• a potential negative-cash or liquidity event forecast in the shorter term
• dependence on borrowing or short-term credit that may be withdrawn
• dependence on third-party support that is not legally binding or comes from a financially weak party
• a forecast covenant breach where the lender’s response is uncertain
• near-term refinancing that may be difficult to secure
• actual or forecast UKVI non-compliance with a material income effect

When OfS places a provider in Category 4, it will “typically” also make and communicate a formal assessment under Condition C4 that the provider is at material risk of market exit. Where it has made that C4 assessment, it will “ordinarily” issue a student protection direction.

Who gets to find out that the regulator thinks a provider is in this sort of state? Condition C4: Student protection directions says:

The circumstances in which the OfS might judge publication to be in the public interest include (but are not limited to) where it is in the interests of current or future students to have information contained in a Market Exit Plan and/or Student Protection Measures available (for example to enable students to make informed choices about their future plans for study).

One might have thought that one of the bits of information students might want in that informed choices thing would be if their chosen provider is at material risk of going bust, but it doesn’t seem to have happened yet. So who does get to find out?

Detailed provider information in Category 3 or 4 gets shared with DfE where escalating risk could have significant consequences for students or the economy, and may be shared with DBIST and UKRI so they can assess risks to research and innovation capability. And then:

We understand that lenders and others with a financial interest may expect providers in category 4 that are in receipt of a material risk of market exit assessment and/or a Student Protection Direction to share relevant information with them.”

So banks, DfE, DBIST and UKRI might need to know. The students whose lifelong debts could be about to be ploughed into a provider the regulator thinks could go bust soon, not so much.

The Office for “Students”? Come on now.