This blog post appeared on the Wonkhe site in mid-November 2020. Written by Nick Holland, Competition and Registration Manager at the Office for Students, it had been anticipated by a statement by Universities UK the previous day. In this article, UUK clearly aligned themselves with the presuppositions that there is a serious problem with quality in UKHE and that the sector needs to introduce some proper regulating. This plays into widely-held beliefs amplified by some media outlets hostile to universities, and a government which seeks to undermine them along with other pillars of a democratic society like the legal apparatus, a free press and even parliament itself.
It is dispiriting for those of us who have had quite a lot of faith in the UK’s HE regulatory mechanisms from the Quality Assurance Agency to the internal procedures of validation and periodic review that operate within all universities. Less able to command confidence has been the government’s own regime of the Teaching Excellence Framework, operated by the Office for Students.
Nevertheless, Nick Holland, the author of the piece, appears innocent of these established structures. We apparently exist in some post-lapsarian quality vacuum which needs to be pumped with new regulations, about which OfS has launched a consultation. And so OfS promises to act on new proposals, even if it requires a temporary adjournment of its other preoccupations: freedom of speech and grade inflation – another piece by Nick Holland.
So below, with some commentary, are excerpts from Holland’s blog. What his choice of discourse does is to install a set of presuppositions about the endemic poor quality of higher education. Furthermore, in this depiction, no evidence can be relied upon apart from a limited set of proxy measures which lend metric infallibility to the conferral of quality. This intervention from the Office for Students seems to reverse several years of avowed ‘light-touch’ regulation in which oversight enabled universities to operate their own bureaucracy of quality assurance and enhancement. But now, the principal metric to be trusted to certify the worthiness of higher education is that of graduate salaries. This is the fulcrum which has elevated the concept of higher education as private good while depressing the notion of higher education as public good.
Excerpts from Holland in grey and interpretation in green
While we had planned to consult on our approach to quality and standards in any case, we will of course draw on our experience of regulating through the pandemic in our future regulation of quality and standards.
This was conducted through veiled threats demeaning the quality of online provision with no thought about how we might intervene to support universities. That’s just not what we do.
The OfS has always been able to hold universities and other higher education providers to account for the quality of their courses and the standard of qualifications they award. But these proposals would sharpen our regulatory requirements, raise expectations for quality and student outcomes, and allow us to take action where there are poor quality courses at providers in particular subject areas.
We already have the regulatory framework well embedded in practice and working well. But since the bar for moral panics has gone way north in 2020, we thought we’d create a bit of spontaneous drama.
Quality and standards
Also included are secure standards – so students can be assured that their degree will stand the test of time – and successful outcomes. Subject to consideration of responses to the consultation, we would be looking to use these definitions as part of our regulation – underpinning the baselines we set which all providers must meet in order to be, and remain, registered with us.
Of course, the enduring worth of your degree would be best ensured if we were committed to ensuring that your HEI continues to function. Instead, we are committed to ‘the market’ and providing registration to new, ‘challenger’ institutions which are awarded degree awarding powers almost immediately. It’s hard to imagine a better way to undermine the hard-won accreditation of your university. And what do we mean by ‘outcomes’? Well, that changes all the time. Sometimes it means ‘good degrees’ but then we clamp down when universities give too many of them. We’re a bit clearer what it means this month later on.
Crucially, we are also saying that all higher education providers must provide quality for all groups of students. That means two things. First, if we are worried that certain groups of students are being adversely affected, we can swiftly intervene. Second, we are saying – unequivocally – that is not acceptable for providers to use the proportion of students from disadvantaged backgrounds they have as an excuse for poor outcomes. Doing so creates a skewed playing field, where poor performance for disadvantaged students is effectively allowed. That is untenable, and unfair to those students who have often overcome the odds to enter higher education. Obstacles to attainment for these groups need to be removed and not hidden behind.
See what I did there? First I install a presupposition that not all HEIs provide a quality education for all students. That charges universities with the responsibility to fully compensate for the social, educational, cultural and systemic inequalities that particular groups of students encounter. For example, the long periods of missed education that disabled students or care-experienced students have faced. And don’t make excuses for the alienation that many BEM or gay students have experienced all through school – that’s up to universities to fix. It’s helpful to scapegoat universities as it makes us popular with government when we undermine public trust in them.
The plans also allow us to intervene at a subject level if we have concerns. This intervention really matters. Most universities and other higher education providers offer high quality higher education across the board.
I had to say this. But important to rattle that sabre every time I throw them a compliment.
But at some providers, we have been concerned about pockets of low-quality provision. Being able to intervene at subject level will make a real difference. As well as assessing data on student outcomes we will also continue to welcome notifications from students alerting us to issues and concerns about the quality of their course.
Obviously, you’d be better making your views known through the various structures available at your HEI, from course committees, to student unions or even the NSS. But here at OfS, while we don’t endorse ‘cancel culture,’ we do approve of snitch culture, and we have always envied the direct reporting line offered by ‘rate your professor’.
Choosing a section title that’s maximally offensive especially during a pandemic.
Ensuring students have every opportunity to achieve successful outcomes on their courses remains an important OfS priority. That is why we are focusing on the number of students who progress to the end of their course and go on to managerial and professional employment or higher-level study. We are proposing to update – and toughen – our requirements for the minimum performance we would expect from any university or other higher education provider.
I told you we’d be clearer what ‘outcomes’ means. In 2020, we’ve pretty much settled on it meaning getting a well-paid job. Because we want students to pay back their loans. Yes, we’ve reduced the whole university experience to pretty much that.
Deciding on the numerical values for these minimum baselines will take time and be subject to further consultation, but we will have higher expectations for providers for all of their students.
I think we can guess what that baseline will be…because we want students to pay back their loans.
These are important proposals, which will help to properly protect students. Please do take the time to have your say in the consultation, which runs from today until January 12.
Don’t waste your time. We’ve already decided.
That subject level data again…..
It’s fascinating to trace the meandering semantics and pursuit of ‘low quality degrees’ over the years. It has meant many things, from accusations of ‘lamentable’ teaching to complaints that too often degrees do not lead to high-paying jobs. While the government boldly alleges poor quality of provision and outcomes in the public HE sector, by contrast, they are happy to support a favoured ‘challenger institution’ by conferring (via QAA) degree awarding powers on the Dyson Institute of Engineering and Technology before it has even had a graduating cohort.
Such indulgence is not bestowed on other institutions and an assemblage of metrics must be found to identify courses that the government rather wishes would disappear. Chief among them, we suspect, might be media studies, gender studies, creative arts and the more critical humanities and social science subjects generally.
David Kernohan of WONKHE (30th November) writes that OfS were due to publish data and a report entitled Start to Success representing the latest attempt to devise a diagnostic quality tool. To save them the trouble, Kernohan has produced a draft version mapping data points representing all HE courses in the UK against projections of non-continuation of students on courses and data from Graduate Outcomes on “highly skilled” graduate employment. Kernohan himself suspects that this metric may be low quality.
What we find is that many of the courses the government denounces, or that universities have been busy eradicating, perform well against these metrics. In the lower quadrant of the quality mapping are quite a lot of law, business, civil engineering and computer science courses, while in the higher quadrant are many courses in Arabic, Classics, English and Geography. Also, some courses at higher status universities manifest surprisingly low scores, while some less-favoured courses like media studies at lower-ranked universities turn up scores above 9/10. Like Kernohan, I am not attempting to confer credibility on these metrics; instead we need to recognise that in searching for ‘low-quality courses’ to liquidate in the name of regulatory scrupulosity, the casualties may not be the government’s preferred candidates. If the government wants to purge those courses which develop critical questioning and an awareness of social justice, then coercion and apparent metric infallibility will not deliver that result. They will have to emulate the more authoritarian approach adopted by Victor Orban in Hungary. They will need to name the courses they disapprove of and ban them. I wonder how close we are to that eventuality? The culture warriors are laying the groundwork and a receptive post-truth society might see it through.