Vice-chancellors in England have warned the Office for Students that its next three-year strategy lacks “vision” and risks drifting from its formative mission to champion students’ interests.
The “independent” regulator risks “becoming a vessel for multiple, potentially contradictory policy agendas”, the vice-chancellors have warned.
The criticism comes from Universities UK, which published its response to a consultation on the next OfS three-year strategy, set to run from 2022 to 2025.
UUK said the new strategy’s “wide-ranging and numerous” targets suggests “a lack of clear focus” at the top of the OfS.
That the strategy does not pay enough heed to students’ interests is a fundamental criticism levelled by UUK. The vice-chancellor body criticised the OfS strategy for only “explicitly” including student engagement on two occasions.
“Good regulation, as set out in the Regulators’ Code, needs to be driven by the interests of those the regulation is seeking to protect,” UUK said, warning: “Student engagement is largely absent from the document.”
UUK recommends the regulator following the consultation explains “how students will be involved in the ongoing development and implementation of the strategy and its goals, and how their views will be used to shape its priorities and regulatory approach”.
The lack of consultation with students risks allowing the regulator to drift from the policy areas that matter most, UUK suggested.
It warns the OfS leadership – which is set to change later this year when chief executive Nicola Dandridge departs in April – that the “strategy lacks an overarching vision for the OfS itself as a regulator”.
“There is little that is new in the strategy or that considers how, as an organisation, the OfS will operate, respond to new and emerging issues, and establish itself as an independent voice acting in the interest of students,” UUK added.
OfS must focus on issues ‘that matter to students’
The other primary UUK criticism of the strategy is its scope and scale. “This is in part a reflection of external and legislative developments, for example, the inclusion of freedom of speech and levelling up. But the OfS must consider how to be effective in managing a diverse and growing portfolio while not overloading itself or providers and staying focused on issues that matter to students,” said UUK.
Successive ministers have asked the OfS to monitor freedom of speech, unconditional offers, antisemitism, grade inflation, financial sustainability, digital poverty, reportable events, online learning, access and participation and even collect data on the number of students catching Covid-19 while at university.
On the instruction of ministers, the OfS is overseeing reviews of the National Student Survey, a framework for quality and standards in education, besides much else. The regulator has given universities in England a year to change their mark schemes to require students to demonstrate proficient written English to get top marks – and a year to urgently review how they handle sexual assault and harassment cases. The OfS is consulting on its new strategy for regulation.
The regulator of higher education institutions (HEIs) in England has vowed in its next strategy to be “uncompromising in intervening and imposing robust sanctions” on “those universities and colleges that are letting students down by providing inadequate teaching and support”.
The vice-chancellor body said the risk of so many different objectives was the potential for OfS agendas to clash. For example, promoting access to HE while at the same time imposing tighter outcomes-based regulation on student progression. “Too strict a focus on outcomes may make providers more risk-averse in their admissions decisions and local partnerships,” UUK warned.
UUK also accused the OfS of “inadvertently” damaging the reputation of HE in England by focusing a disproportionate amount of time focusing on “non-compliance”, which “risks misrepresenting the sector as problematic”.
In an apparent contradiction to statements made by Dandridge in spring 2021, UUK said it thought the future director for academic freedom and freedom of speech should “have experience of either the higher education or legal sector”. In a statement given to MPs, Dandridge said she did not believe it a prerequisite that the future director – who will oversee contentious issues of freedom of speech – have legal training.