Joint Funding Councils’ response to QAA proposals for new quality assurance framework
1. This note sets out the views of the three Funding Councils, HEFCE, SHEFC and HEFCW, on the latest QAA proposals for a new quality assurance framework in HE. Those proposals are contained in the QAA paper attached to John Randall’s letter of 17 August to the Funding Councils. They have been considered by both the Board and the Quality Assessment Committee of the HEFCE and the SHEFC, and by the HEFCW Quality Assessment Committee. The Department of Education, Northern Ireland has also been kept informed of the progress of the discussions.
2. The three Funding Councils are grateful for the way the QAA has kept in close touch with us as it has developed its thinking in the light of the responses to the March consultation paper. We appreciate the efforts the QAA has made to articulate an overall framework sensitive to the various stakeholders. The Agency has set itself an ambitious agenda, and we are anxious to work closely with it in devising an effective new framework. We believe that progress is being made, and congratulate the QAA on its perseverance.
3. Our starting point is the statutory responsibility of the Funding Councils to secure that provision is made for assessing the quality of education in the institutions we fund. The attached paper sets out in detail the characteristics which any new quality assurance approach must have in order to meet the requirements of the Funding Councils, in terms of accountability, public information, enhancement of quality, linking funding with quality, and value for money. It assesses the extent to which the latest proposals meet those requirements, and the aspects on which we would welcome further discussion and clarification. This note summarises the main points.
4. Overall, we believe that the proposed QAA framework can be developed in a way which meets the Funding Council requirements. A great deal of detail remains to be worked through. Some of the proposals are better articulated than others, and it remains to be demonstrated that the many innovative aspects can be effectively delivered in practice. So there is still a long way to go. Moreover, the framework would meet some of the Funding Council requirements noted in paragraph 3 better than others. With respect to accountability and enhancement of quality, the framework can clearly be developed in a satisfactory way. The requirements for public information, linking funding to quality, and value for money could also be developed in a satisfactory way subject to some modification of the current proposals as described below and in the attached paper. Subject to these important caveats, the latest proposals represent a substantial move forward from the original consultation proposals.
5. There is much that we welcome in the proposals as representing potential advances, including:
- The intention to develop the framework of qualifications proposed in the Dearing report.
- The emphasis given to course descriptions and the learning outcomes expected for students as part of the proposed programme specifications.
- The effort to define subject benchmarks and threshold standards. This is no easy task. But the sector will lack credibility if it is not able to define these.
- The proposed code of practice on external examining.
- The concept of an academic reviewer able to work with a number of institutions, and to provide QAA with reports on programmes which will be published.
- The proposed code of practice on student support and the maintenance of standards.
- The proposal for a closer relationship between institutional review and the review of quality and outcomes at subject/programme level.
6. The scale of the changes envisaged, and the inter-dependence of the component parts, mean that we cannot expect to move immediately to full implementation. Clearly we should move to the new framework as rapidly as is feasible, and should then keep the procedures as stable as we can, to minimise turbulence for institutions. But for example, it is only when the qualifications framework, benchmark standards and programme specifications are in place for a given subject area that reports on outcome standards can be prepared in the intended style. Institutions will want to be assured that duplication of effort will not be caused by operating two review systems in parallel.
7. We agree with the objective of placing increasing weight on institutional self-assessment. But that can happen only when, and to the extent that, its reliability and consistency are demonstrated. It is right that there should be a balance between self-assessment and external review. But getting the right mixture is more important than reducing the bureaucratic burden per se. We are keen to see the latter, but not at the expense of the rigour of the quality assurance process. We therefore start here from the position that the Joint Planning Group reached, which was that the external review process should be lightened as the reliability of the self-assessment improves. We see, at the level of the institution, the balance being progressively tilted towards self-assessment as the institution wins the confidence of the Agency. The internal processes will need to have some measure of consistency between institutions in order to secure comparability and robustness of judgements.
8. We believe that the QAA proposals would satisfy the requirement that HE institutions be held to account for the quality and standards of their provision. Meeting the needs of different stakeholders for information is a complex area. We think the QAA proposals are capable of being developed in a way which would meet those needs, and we welcome the fact that the QAA will be responsible for the publication of the material that is disseminated as part of the Agency’s formal procedures, whether internally or externally generated. But there are several as yet unanswered questions here. In principle it is highly desirable that the QAA assessments should include summative quantified ratings as well as narrative descriptions of strengths and weaknesses. But we do not under-estimate the difficulties of deriving ratings within the proposed framework which can robustly withstand legal challenge, particularly if linked to funding in Scotland and Wales. We therefore need early discussion of how we can build on the current grading systems to establish rating methods which are simultaneously simple, informative, valid and fair.
9. We believe that the proposals could generate an acceptable basis for helping institutions enhance the quality of their provision, as distinct from merely assessing it. The particular question here is how the subject overview reports can be made most useful if derived from assessments of differing vintage and related to different subject groupings proposed by individual institutions. This may well point to using the same subject units to assess both quality and standards.
10. The proposals would provide a sufficient basis for linking funding and quality using the methods currently envisaged by HEFCE, because the proposals would identify unsatisfactory provision. For HEFCE, funding incentives for high quality provision would be delivered through separate bidding programmes. It is not evident, however, that the proposals would deliver the type of link which SHEFC and HEFCW have hitherto made by means of a formulaic element, driven by QAA quality ratings, in mainstream funding grant. This will need further consideration.
11. Although the proposals have not yet been costed, we believe they could in principle deliver better value for money, by placing greater reliance on institutions’ internal procedures and evidence, and by greater selectivity in targeting external scrutiny where it is most needed. This, however, implies an investment by institutions in the robustness of their own procedures. And there will need to be constraints on the discretion of institutions to propose their own subject review cycle if we are to avoid unacceptable gaps in the provision of public information.
12. The proposed framework now needs to be tested by a rigorous trialling. We welcome the opportunity provided in Scotland and Wales to develop the detail of the new arrangements, although it is important that we continue to work towards a framework which can apply in all parts of the United Kingdom. Even though the current quality assurance system is scheduled to continue in England until the end of 2000-2001, the HEFCE intends to play its full part in working with colleagues to develop an acceptable new framework as quickly as possible. To a large extent the future acceptability and success of the Agency in promoting the changed arrangements will be judged by these first operations. The three Funding Councils need very quickly to agree with the QAA the approach to trialling, including design, implementation timetable, milestones and targets, and evaluation methods.
13. The proposals have, quite rightly, been devised so as to be appropriate for institutions in the higher education sector. HEFCE and HEFCW also have responsibility for funding certain courses of higher education in further education colleges, where lead funding responsibility for the institution as a whole rests with the FEFC/FEFCW. HEFCE will shortly assume responsibility for funding HE courses in a much larger number of FECs. HEFCE and HEFCW need to consider separately with the QAA the application of the proposed new framework to HE in FECs, to ensure co-ordination with the quality assurance procedures of the FEFC/FEFCW and the validating bodies. This issue does not arise in Scotland.
14. The three Funding Councils look forward to further discussion with the Agency as soon as possible to work through the next level of detail in developing the proposals.
Last updated 5 October 1998