UUK addresses OfS consultation on integrity and stability

UUK responds to the Office for Students (OfS) consultation on the integrity and stability of the higher education sector in England

Universities UK (UUK) has published its response to last month’s Office for Students (OfS) consultation on the integrity and stability of the higher education sector in England.

The association queried the potential undermining of individual institutions’ autonomy, and asked for clarity on what would constitute a breach of the OfS’s proposed regulations designed to support the sector

“UUK supports the OfS’ objective of providing support for the sector but there must be clearer guidelines over what would constitute a breach of the proposed regulations,” said Alistair Jarvis, chief executive of Universities UK.

“Failure to do so could harm the significant progress made in opening up our universities to students from more diverse backgrounds. It is also imperative that universities are able to retain their autonomy. The regulator must ensure any targeted actions to support student and university stability are strictly time-limited while the sector continues to be impacted by Covid-19.

Any new regulations shouldn’t be to the detriment of students with the potential to benefit from going to university where they can develop knowledge, credentials, networks and skills for successful careers, and personal growth – Alistair Jarvis

“It is vital that the admissions process remains fair, transparent, and in the best interests of all students at this unprecedented time. Any new regulations shouldn’t be to the detriment of students with the potential to benefit from going to university where they can develop knowledge, credentials, networks and skills for successful careers, and personal growth.

“Similarly, courses that accept applicants based on factors beyond academic results – including interviews, skills test and auditions – and may be disproportionally penalised under the OfS’ proposals, should not be.”

The full UUK response states:

• UUK does not support the full extent of new OfS regulatory powers as outlined in the consultation. The scope of any new regulatory intervention should be targeted more effectively and focus solely on supporting stability for students, using the 2020/21 student stability measure as the central guiding policy intention.

• The OfS should not obtain powers to be able to take retrospective action against universities covering activity as far back as 11 March 2020 – but only where any new condition is breached in terms of admissions behaviours for UK and EU-domiciled undergraduate admissions from the date the consultation was launched (4 May 2020) or where a university clearly breached the specific terms of the admissions moratorium since it was first introduced on 23 March 2020. UUK argues that the wording of the consultation suggests all behaviour that could negatively affect the sector would be a breach, not just behaviour that is specifically a response to the pandemic. It asked that the words ” in response to the pandemic” be included.

• The OfS must provide an unequivocal commitment that any condition of registration would in fact be time-limited, and not simply extendable via a follow-up consultation.

• The OfS must provide clearer guidance on what would constitute a breach of the condition. Terms such as “potential”, “the interests of students” and “incentives” are, says UUK, too vague and pose a risk to the sector’s ability to adapt and support students.

• UUK believes that the proposals would damage recruitment to courses where factors beyond actual academic attainment are central to admissions decision making, and risk creating new limitations on efforts to promote access or meet Access and Participation Plan targets which must be avoided. It says the proposals risk a conflation between contextual offers (used to widen access) and what OfS has previously labelled ‘attainment offers’.

• It is also essential that English providers are able to compete effectively within the UK and global student recruitment markets during and beyond the pandemic. UUK urges the OfS to avoid any action which inhibits the ability of English providers to compete effectively. Any new measures should support student choice across the whole of the UK rather than in England alone.

“The UK is a popular destination for international students but English universities must be given the opportunity to compete with global student recruitment markets if they are to remain a first-class port of call now and in the future,” said Alistair Jarvis. “A change in registration practices risks harming this and student choice.”


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