Well, CHEE, anyway.

At a time when HEFCE are consulting on the future of future of quality assurance in the HE sector, and have invited views on a discussion document:

The discussion document contains questions on quality assessment that aim to stimulate wide-ranging discussion and debate on important high-level issues. Its purpose is to explore the deep, critical questions that need to be addressed before the more practical issues surrounding the design and implementation of any new quality assessment arrangements can be considered.

In the second consultation document we will set out clear options for the scope of future quality assessment activities. This will cover the way in which these are underpinned by the powers provided through the statutory and other duties of the funding bodies.

and large numbers of staff at my institution will be spending half a day grappling with the questions in the review, then Universities UK have published their own report calling for changes to HE regulation.

Key recommendations from the report include:

A new approach for protecting the student interest in the rare event of institutional or course closure
The establishment of a register of approved higher education providers, giving the current higher education register greater regulatory status
The establishment of a new Council for Higher Education for England, evolved from the Higher Education Funding Council for England (HEFCE), which would lead and coordinate mechanisms to provide assurance of quality, equity and sustainability in higher education (in addition to its funding role)
The indication that necessary changes should be made to primary legislation in order to implement the proposals in this report

Some Cheese

Pam Tatlow of Million+ has commented on the report, saying:

“There are serious doubts about whether any party will consider a higher education Bill to be a high priority early in the life of the next Parliament and much more likely that improvements in regulation or changes to the fee cap will be delivered by statutory instruments rather than primary legislation. However there are risks in arguing that the regulatory role of HEFCE should be expanded.

“HEFCE remains a significant funder in terms of research as well as providing some direct grant for teaching and its funding role could be increased if fees were reduced and direct grant restored. It would be highly unusual for a regulator to have a major role as a funder. Given there are so many unknowns, proposals to extend HEFCE’s regulatory role may be premature.

“It is also difficult to understand the rationale for subsuming the Office of Fair Access into HEFCE bearing in mind the primary legislation that underpins OFFA. An independent access regulator has been supported by all of the main parties and it is unlikely that any proposal to change this will find political favour after the election.”

UUK propose that the remit of CHEE should be

Funding teaching, research and knowledge transfer
Maintaining the register of higher education providers
Applying and monitoring conditions attached to registration (including continuation of responsibilities for ensuring provision is made for assessment of quality) and applying appropriate sanctions where appropriate and necessary

Leading the coordination of higher education regulation
Working in partnership with the sector to develop mechanisms for student protection

In particular on quality assurance, the report proposes that QA:

i. be premised on co-regulation and co-ownership
ii. be responsive to the new environment, particularly the needs of students, and adopt an approach that is risk based and equitable between different providers
iii. represent value for money for its funders and keep regulatory burden to a minimum
iv. continue to form part of a UK-wide system
v. have a clear focus on academic quality assurance rather than other aspects of the full student experience
vi. have effective and appropriate governance and transparency for students and other relevant stakeholders
vii. ensure quality assurance expectations at a European level can continue to be met and the significance of transnational education recognised.

 

Th report is strongly supportive of the autonomy of higher education institutions, and in particular the principles of co- and self-regulation. While these are defended, and it is noted that equality dies not necessarily mean equity, the sector does need to remain aware of the questions being asked of it by the Competition and Markets Authority and by consumer groups such as Which?.

Clearly as the HE landscape continues to evolve and become more diverse, and in advance of a possible change of government, then reviewing how we regulate and assure HE is critical. The hope must be that any changes to QA are such that they deliver a process that supports enhancement of teaching and learning as well as research, rather than generating a quality “industry” that generates paperwork, but does little to impact on the majority of participants in HE, either staff or students.

An interesting week for the wonks, as HEFCE announced that it was reviewing the arrangements for quality assurance in the sector, stating:

“UK higher education is undergoing rapid change. Our future quality assessment arrangements must continue to be internationally respected, to have the confidence of students, and to support a world-class HE sector.
We are looking to develop innovative approaches that are risk-based, proportionate, affordable, and low burden. Any new arrangements must build on established strengths and good practice, including institutions’ own robust quality assurance systems, and reflect the values and cultures of higher education. They will also need to demonstrate value for taxpayers’ and students’ money”

and after feedback from various stakeholders, will put the work out to tender.

Obviously, QAA (the current provider of Quality Assurance) had something to say:

“QAA has internationally recognised expertise in providing quality assurance and enhancement to an exceptional standard. In recent years, we have continued to adapt the quality assurance framework to meet the needs of a growing and dynamic sector, working with HE, FE and alternative providers. We look forward to continuing the development of quality assessment, protecting the public interest and supporting the UK higher education sector’s international reputation for excellence.”

Clearly assuming they’ll get the contract, or at least pointing out what a good job they have done so far.

And our university mission groups chipped in, with somewhat inevitable responses.  The Russell Group said:

“Universities with a strong track record of success which have been delivering high quality education for a long time should be subject to considerably less inspection and bureaucracy than newer institutions.

“Our universities will not flourish if they are over-regulated. Resources should be focused where problems of quality are most likely to occur.”

While million+ came up with:

“Vice-Chancellors will clearly want to be involved in this review but HEFCE needs to be careful not to throw the baby out with the bathwater. While there have been concerns about the QAA’s modus operandi, the system is certainly not broken and has the advantage of being UK-wide in scope and internationally recognised.”

I think the two mission groups said exactly what we would expect them to. I do wonder who the Russell Group are thinking of as “newer institutions”. That wouldn’t be former polytechnics with a 100 years of HE history would it? Or does it mean the real new kids on the block, the private providers and FE providers of HE?

Quality assurance arrangements may seem arcane, but all of this does matter, and as David Kernohan identifies over on his blog, it matters to every academic. Quality assurance can be seen as an evil which is inflicted upon institutions, and by institutions onto their staff, but the basic principles outlined in the QAA code of practice are eminently reasonable.

The devil of course is in the details: firstly how individual universities choose to interpret the code and operationalise quality through a series of managerial interventions, and secondly how an review of a University’s “quality” can be anything more than a review of its QA processes.

Seeking a system that is “risk-based, proportionate, affordable, and low burden” might come as pleasant music to the ears of someone buried deep in generating a monitoring report that will be read by few, and followed up by fewer, but for the burden to be reduced internally within universities, then a clear steer will be needed on what processes can be simplified and reduced (or, dare I say it  – removed). If the assessment regime is to be risk based and proportionate, then maybe institutions need to look inside to their own processes and make sure that these too are risk based and proportionate.

It would mean developing criteria to assess and score risk – but with the development of data on award performances in terms of inputs and outcomes, student evaluations, coupled with a business risk analysis (with on-campus teaching low risk, compared to overseas in a language other than English), then this should not be ijnsurmountable.

It would mean a QA system where an approach of “one size fits all” would no longer apply, but it might allow some staff to spend less time on activities that can become mindless busywork, and focus more on the real work of a university – generating knowledge and helping students to succeed.