The chief executive of the Office for Students (OfS) said she is “determined to stamp out any pockets of low quality” as she announced a consultation on proposals “to raise the bar on quality and standards in higher education”.
Nicola Dandridge today (17 November) announced a consultation on the monitoring and regulatory role of the OfS, which will be followed by “more detailed proposals” in the new year.
The OfS is proposing “new definitions of quality and standards”, which relate to university admission procedures, course content, teaching, learning resources, academic support, student outcomes, qualification standards and career progression.
Subject to the results of the consultation, the OfS seeks to set “more challenging” baselines for student outcomes. Although the consultation document omits any precise figures for the new baselines, the OfS states its intention to set thresholds “at a level that would appear to a student, a parent, a reasonable layperson, or the taxpayer, to represent a high-quality baseline and so a minimum acceptable level of performance”.
Under existing rules, the HE regulator requires successful institutions to average a 75% progression rate for full-time first-degree students from the first to the second year of study. This rule, like the other statistical measures, was introduced during the initial registration process, which “used numerical baselines that were set generously and resulted in some providers satisfying condition B3 despite delivering outcomes for students that we judged to be of concern,” the OfS consultation states.
“Our approach during the initial registration process meant that some providers were registered because we judged their performance to be acceptable in aggregate, even if there were pockets of performance that may have fallen below a numerical baseline,” the consultation continues.
“This approach had a direct impact on students: on the basis of the most recent data for registered providers, there were almost 65,000 students in 2018-19 on courses that would not have met the numerical baselines we used for registration if we had assessed each of those courses against the relevant baseline.”
According to OfS estimations, around 3% of the total student population in 2018-19 were on courses that did not meet its baselines across all subjects, student cohorts and year groups. The consultation suggests the regulator is considering introducing a 90% continuation rate threshold, although it concedes this may be “too high”.
Our manifesto promised to explore ways to tackle low-quality courses, and we continue to support the Office for Students on this. We must have robust regulation of our higher education system, which includes strong action if standards slip and principles which protect students’ interests
– Michelle Donelan, universities minister
The OfS will implement its baselines at a ‘granular’ level, which means universities will need to achieve thresholds across all subject levels and student groups, including those from underrepresented backgrounds.
“Our view is therefore that an approach to regulating student outcomes that resulted in setting a lower regulatory standard for students from underrepresented groups would risk baking their disadvantage into the regulatory system,” the consultation document explains. “We recognise that this presents a challenge for higher education providers: if they are to recruit students from underrepresented groups, they must do so having understood the commitment they are making to supporting these students to succeed.”
Universities will need to demonstrate they can achieve the same goals no matter what the composition of its student cohort. “Our view is that a provider that recruits students from [underrepresented] backgrounds is obliged to ensure that they have a high-quality academic experience and successful outcomes on the same basis as students from more advantaged backgrounds,” the regulator continues.
According to the OfS, students from underrepresented groups are “disproportionately concentrated” in providers with weaker outcomes, which it said necessitates the policy imperative to improve standards.
The OfS will also continue to measure access and participation targets and progression to professional employment or further study. It will track these figures using the Hesa student record collections, the Graduate Outcomes survey and the longitudinal educational outcomes (LEO) dataset, which links graduates tax data to their higher education career.
Alongside higher baselines, the OfS seeks to create new ‘direction of travel’ indicators “to allow the identification of possible increased risk before this crystallises”. The list of indicators of risk includes “a sudden drop in applications from international students”, industrial action, increased pension costs, borrowing costs, forecast financial position, staff to student ratio and the size of the student population.
The regulator may also begin publishing its indicators for individual providers “to show their performance in relation to the numerical baselines”.
Courses delivered above A-level will subject to monitoring, including higher technical education and apprenticeships. The system will also extend to include transnational education; approximately 600,000 students studied outside the UK for awards offered by 114 registered English higher education providers in the 2018-19 academic year.
The OfS consultation follows plans from Universities UK to draw up guidance on identifying and improving “potentially low-value or low-quality courses”. The 11-strong advisory group of vice-chancellors will develop a sector-wide charter “to address concerns that some could deliver more for students, taxpayers, and employers,” said Prof Julia Buckingham, president of Universities UK and chair of the advisory group.
Ms Dandridge said: “These proposals strengthen our ability to intervene where we have concerns. We have previously been clear that we are determined to stamp out any pockets of low quality, and these proposals would not only raise the bar in terms of the quality overall but would enable us to monitor quality at a subject level, as well as taking into account issues which might be affecting students from particular groups.
“We are also making it clear that we do not accept that expectations should be lowered for students from disadvantaged backgrounds. All students are entitled to the same minimum level of quality and outcomes, and it would be untenable to have a regulatory system which allowed universities to recruit students from underrepresented groups but then set lower expectations for their success.”
The regulator-in-chief said the OfS would use its “full range of powers if we consider that any of our registration conditions are breached”.
This is second major consultation launched by the regulator this autumn, after it began its review of regulatory burden, including the future of the National Student Survey (NSS), in September. “We remain extremely mindful of the need to ensure proportionate regulatory burden,” Ms Dandridge said today. “Universities and other higher education providers offering high quality higher education across the board will find that our proposed approach to quality places minimal regulatory burden on them.”
The consultation is in response to a 2019 Conservative manifesto pledge to raise standards in higher education.
Universities minister Michelle Donelan said: “We want all university students, regardless of their background, to benefit from high quality, world-leading higher education. Our manifesto promised to explore ways to tackle low-quality courses, and we continue to support the Office for students on this.
“I am pleased that the OfS aims to raise the bar on quality and standards. We must have robust regulation of our higher education system, which includes strong action if standards slip and principles which protect students’ interests.”