Report of the Quality Assurance Framework Review Group: Phase three outcomes: Assessment of the impacts of reviews of collaborative provision

To:

Heads of HEFCE-funded further education colleges, Heads of HEFCE-funded higher education institutions, Heads of universities in Northern Ireland

Of interest to those responsible for:

Quality assurance and collaborative partnerships

This document sets out the outcomes of phase three of the review of the Quality Assurance Framework. It includes recommendations for revisions to the methods used by the Quality Assurance Agency for Higher Education for auditing collaborative provision and for improved communication between agencies.

Contents

• Foreword from the Chair
• Executive summary
• The Quality Assurance Framework and review process
• QAF review phase three – impacts of reviews of collaborative provision
• Key findings
• Annex A QAFRG terms of reference
• Annex B Membership of QAFRG
• Annex C Summary of recommendations
• Annex D Summary of SQW report
• Annex E List of abbreviations

Executive summary

Purpose

1.         This document sets out the outcomes of phase three of the review of the Quality Assurance Framework (QAF). It includes recommendations for revisions to the methods used by the Quality Assurance Agency (QAA) for auditing collaborative provision, and for improved communication between QAA and other reviewing agencies.

Key points

2.         The QAF Review Group (QAFRG)¹ commissioned SQW Consulting to carry out research into the impacts of reviews of collaborative provision on higher education institutions (HEIs)².

Main findings

3.         Reviews of collaborative provision are an integral part of the overall quality assurance infrastructure. As such, they protect public funding and students’ interests, ensure public confidence in collaborative provision, and maintain the global reputation of English higher education (HE) while still enabling HEIs to maintain autonomy. Safeguarding the public interest has been a key focus of the group’s work.

4.         The key benefits of reviews are enhancement of an HEI’s public reputation and validation of standards. Other benefits, many of which stem from the institution’s preparation for the review, include: opportunities for institutions and their partners to reflect on their provision; a strengthening of HEI-partner relationships; and raising the profile of the provision within an institution.

5.         Sector views are mixed on whether collaborative provision audits (CPAs) should be separated from institutional audit. Some institutions perceived separate CPAs as more effective for reviewing collaborative provision than an exercise within an institutional audit, although there is a risk that there will be a lack of coherence with other QA processes. There is some uncertainly as to the definition of ‘large and complex’ provision, although QAFRG recognises that deciding whether or not an institution fits into this category will be subject to discussion between QAA and the institution concerned. There were mixed views as to what the length of time should be between institutional audit and CPA.

6.         Many HEIs perceived that there was significant duplication in the information provided for institutional audit and for CPA. Some HEIs were concerned that requirements for reviews of collaborative provision would duplicate requirements of IQER (Integrated Quality and Enhancement Review), the new method for quality assurance of HE delivered in further education colleges.

7.         Although QAA review was considered to be effective, there were mixed views on whether or not QAA activity was proportionate to the perceived risks to quality of collaborative provision. There were suggestions that collaborative provision should be judged according to a ‘continuum of risk’ and reviews should be scaled accordingly. The context of the provision, including the institution’s own experience of collaboration and risk management processes, should be taken into account when judging risk levels.

8.         While any review of collaborative provision adds to an institution’s costs, separate CPAs in particular were perceived as being highly resource-intensive. Few HEIs in the case study were able to identify total costs, so it was not possible to determine the average cost of a collaborative provision audit or to determine whether or not it represented value for money.

9.         Audits of overseas provision as carried out by QAA are not formally identified as part of the QAF and were therefore excluded from the research. It is recognised however that equity and comparability between home and overseas provision are important.

10.       For the future QAA has proposed a tripartite approach to reviews of collaborative provision in which, for most institutions, collaborative provision will be considered as part of institutional audit. Large and complex institutions with substantial collaborative provision will receive a separate audit and large institutions with complex collaborative arrangements will be subject to a ‘hybrid’ model in which collaborative provision is reviewed as part of institutional audit but enhanced by partnership visits. The HEI representative bodies have been consulted on this model. QAFRG judges that the model is a good base on which to proceed with revisions to reviews of collaborative provision, but the recommendations of this report should be taken into account, in particular the requirement to use a more risk-based approach.

11.       HEIs have relationships with a variety of professional, statutory and regulatory bodies (PSRBs), which tend to offer accreditation or professional recognition which may be vital for a particular programme. PSRB information requirements normally tend to be at the subject level, and therefore do not directly overlap with QAA requirements. However, the need to provide the same information in different formats for different PSRBs can be burdensome, and there is a perceived need for greater co-ordination.

12.       Sector Skills Councils (SSCs) are still relatively new. There is some anxiety in the sector that they may impose additional requirements. Some institutions were concerned that the new quality assurance arrangements for health, being drawn up by Skills for Health, might be unnecessarily burdensome. The new body with responsibility for SSCs, the UK Commission for Employment and Skills, is encouraged to work with HEFCE, QAA and others to adopt a ‘light-touch’ approach.

13.       Employer engagement is not yet seen as an area that has many review requirements, although the quality assurance issues raised are being considered by the HEFCE task group on employer engagement.

14.       The Office for Standards in Education, Children’s Services and Skills (Ofsted) inspection requirements for initial teacher training provision were perceived as particularly burdensome, but QAFRG welcomed a recent consultation from Ofsted proposing that inspections should be proportionate to risk.

15.       QAFRG’s overall conclusion is that, in general, all reviews of collaborative provision should:

• take a risk-based and proportionate approach
• avoid undue burden and duplication
• take account of other processes.

Recommendations

16.       A complete listing of the recommendations is at Annex C. In summary:

a.         QAFRG have made several recommendations to QAA to review their approach to audit of collaborative provision. QAA have been asked to consider the following, with due consultation with the sector:

• adopting a more bespoke and evidently risk-based approach to audits of collaborative provision, taking HEIs’ own risk management processes into account
• ensuring definitions of ‘large and complex’ and ‘collaborative provision’ are clear
• taking information from other organisations such as PSRBs, and the outcomes of their processes, into account where possible and appropriate
• streamlining information requirements for institutional audit and CPA
• ensuring that requirements for institutional audit and IQER do not overlap
• linking home and overseas audits more clearly
• ensuring students are effectively and appropriately engaged with the process.

The proposed tripartite model could be a good starting point for development of the above recommendations.

b.         To reflect and acknowledge the increasing growth (and hence risk) of collaborative delivery, HEFCE may also need to consider how it might support HEIs in identifying and addressing any risks posed by these activities.

c.         HEIs should ensure that the information about their collaborative partnerships is up to date and is shared with QAA.

d.         All those involved in reviewing collaborative provision in HEIs, including QAA, PSRBs and SSCs, should ensure they adhere to the ‘low burden’ principles of the Higher Education Regulation Review Group Concordat and share information as far as possible. QAFRG welcomes all efforts made to secure greater co-ordination between these bodies.

Action required

17.       The sponsoring bodies fully endorse the recommendations and will be discussing the revisions to the audit method with QAA. The sector will be consulted further on how a risk-based approach to audit might best be taken forward.

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