Introduction

HEFCE, in conjunction with the bodies responsible for funding higher education (HE) in Wales and Northern Ireland, has issued a consultation on future approaches to quality assessment. The consultation document and response form can be accessed here.

Responses must be submitted by 18 September in relation to the proposals as they would apply in England and Northern Ireland or 31 August in relation to the proposals as they would apply in Wales. The document builds on responses received to the discussion paper issued  by the Quality Assessment Review Steering Group in January 2015. It also seeks to establish a common framework across England, Wales and Northern Ireland while accepting that implementation of the approaches will differ in each country given the devolved nature of HE. Pilot activity is to be undertaken in 2016-17 and full implementation in 2017-18.

Key features of the proposals

Key features of the suggested approach are: 

  • a recognition that current arrangements need to be strengthened if core assurances,  in particular in relation to the security and comparability of academic output standards and the student academic experience, are to be provided safely to students, government, taxpayers and other stakeholders;
  • the need to avoid placing a disproportionate burden on providers who can evidence continuing safe custody of standards and quality;
  • the need to identify problems early and address them rapidly in a proportionate way;
  • the need to reflect the fast increasing diversity of the HE landscape and the operating environment for providers.

Strengthening the QA system

The paper proposes three main elements to strengthen current arrangements, while building on current practice.

Strengthening institutional governance

It is proposed that more reliance should be made on institutions’ own review and governance processes, and in return there would be significantly less reliance on periodic review by an external agency such as QAA. This is the aspect of the proposals that has received most publicity. The paper refers to the issue of the new Higher Education Code of Governance issued by the Committee of University Chairs, which emphasises the need for governing bodies to review regularly the effectiveness of their governance arrangements.

However, the paper is not calling for the ending of external scrutiny of providers’ arrangements, but rather for re-focusing of such scrutiny to areas that matter most to students and other stakeholders – such as academic outcomes – and for removing unnecessary administrative burdens.   Accordingly, external scrutiny would continue where a provider sought to enter the publicly funded HE system; where a problem emerged with an existing provider; or where a funding body felt it desirable to have independent advice when scrutinising a provider. Institutions’ periodic review processes would need to contain strong external elements, such as involvement of relevant professional, statutory and regulatory bodies.

The funding bodies would look in the first instance to governing bodies to provide assurances about the academic experience and student outcomes in their annual assurance reporting process. While senates and academic boards would continue to have the predominant role, governing bodies would be expected to challenge management and they  might wish to receive independent advice before providing these  assurances.

Strengthening the external examiner system

While the paper recognises the central importance of external examining as part of a peer driven system of maintaining standards, it calls for the system to be strengthened by requiring external examiners to be trained, supported and registered by an external sector body which is not the funding bodies. It calls for UUK, GuildHe and other sector bodies to take the lead in proposing how these changes could be taken forward.

Data-driven continuous improvement in learning and teaching

The government’s market driven approach to improving quality and value for money in HE has seen a substantial increase in the amount of data collected by HEIs which is relevant in assessing the quality of the student experience and student outcomes. The paper is not advocating the collection of swathes of new data but rather that data “should be collected once but used many times”. The funding bodies would expect providers to make effective use of such data when reflecting on the quality of student experience and outcomes. HEFCE would also use such data in undertaking its routine monitoring of institutions, to inform the discussion at its annual meeting with each provider and, if necessary, to trigger intervention under its existing framework. HEFCE would use its 5 yearly assurance review visit to check the evidence and processes used by governing bodies to produce their annual assurance statements.

Comparability of standards

The paper states that there is a student and public interest in providing better evidence of the reasonable comparability of standards across the UK, particularly at the pass/fail borderline but also at the 2i/2ii borderline. Possible means of achieving this could include:

  • asking academic disciplinary communities to come together to compare students’ work and judge student achievement against the standards set, in order to improve comparability and consistency
  • reviewing the helpfulness of subject benchmark statements
  • requiring external examiners to undertake training
  • asking the sector to produce guidance on the range of appropriate algorithms within assessment regulations.

The broader framework of quality assurance

The paper suggests its proposals should be seen in the wider context of HE quality assurance, on which HEFCE is working closely with BIS. Two particular issues are addressed in this part of the paper.

Excellence and innovation in learning and teaching

While the paper does indicate that providers will be expected to build in a structure for encouraging continuous improvement, HEFCE does not consider the framework it is proposing to be a means of identifying excellence and innovation (although it notes that entry of a provider on its Register of HE Providers can be used as a “kite mark” of basic quality). The government, however, is committed to introducing a “Teaching Excellence Framework”, analogous to the Research Excellence Framework, with this aim in mind. BIS will consult on a TEF in the autumn.

Gateway into the HE system

Currently the UK HE Quality Code sets out the baseline requirements for alternative providers seeking to enter the publicly funded sector in England and Northern Ireland. HEFCE states that it intends to produce a “simpler expression” of this for publication. Although unnecessary bureaucracy would be avoided, there would continue to be an external peer review scrutiny process to assess compliance with the baseline requirements of student academic experience and the robustness of the provider’s governance processes.

Next steps

Providers, whether already within the publicly funded sector or not, will want to respond to the consultation, which is likely to set the parameters for the new quality assessment system for many years to come.

Eversheds has much experience of advising HE providers in relation to challenges to quality assessments by the QAA and other regulatory bodies, and of applications to enter the publicly funded sector or for particular powers such as the power to award degrees. If your institution is considering such issues we would be pleased to discuss how we might be able to help you.

Finally, we have much experience of advising on HE governance matters, including undertaking governance reviews. These are likely to become more significant as the result of the new Code of Governance, whatever the final shape of the quality assessment scheme. In the autumn term we will be holding a thought leadership event on the governance of academic quality, in conjunction with Academic Audit Associates Ltd. We do hope to see Heads of Institution and Chairs of and Secretaries to Governing Bodies at this event.