1. This document reports on the outcomes of, and next steps arising from, the HEFCE consultation ‘A risk-based approach to quality assurance: Consultation’ (HEFCE 2012/11). This consultation on a more risk-based approach to the quality assurance of higher education (HE) in England took place in the summer of 2012.
2. The Government’s higher education White Paper, ‘Students at the Heart of the System’, which was published by the Department for Business, Innovation and Skills in June 2011, invited HEFCE to consult on the introduction of a more risk-based approach to quality assurance, ‘[to focus] the effort of the Quality Assurance Agency for Higher Education (QAA) where it will have the most impact, and giving students power to hold universities to account.’ (White Paper, paragraph 3.19).
3. The ensuing consultation, which closed at the end of July, elicited 130 responses from across the HE sector. The responses showed strong support for the three key principles which were identified in the consultation document as essential for developing a more risk-based approach to quality assurance, namely:
- the retention of a universal system for HE providers which continues to promote enhancement
- an approach which is robust and rigorous, enabling HEFCE to carry out its statutory duty to secure assessments of quality for HE providers that have access to public funding
- an approach which enables students to continue to play a prominent role in assessing their own academic experiences.
4. General support was also expressed for our proposal to use the QAA’s existing method of Institutional Review as the basis of building a risk-based approach, given the success of this new method in ensuring rigorous, robust review which fully involves students, but is proportionate in regulatory terms.
5. We were pleased to receive so many responses to the consultation, from a wide range of interests. In addition, the consultation events were well attended, especially by student representatives. The responses we received to the consultation questions showed wide cross-sector agreement on a range of key proposals, including that steps should be taken to:
- reduce unnecessary burden and achieve better regulation, targeting the QAA’s efforts where they are most needed
- tailor external review to the individual circumstances of providers (a ‘one size fits all’ approach was not seen as appropriate for such a diverse sector)
- continue to involve students fully as central partners in the process, in assessing and improving the quality of their HE experience
- continue to ensure that enhancement is a core dimension of quality assurance
- ensure transparency, for example through the application of clear criteria where appropriate.
6. In what follows, we present a package of measures agreed by our Board, which aim to achieve a more transparent, proportionate and risk-based approach to quality assurance which will target the efforts of the QAA where they will have the most impact. We are asking the QAA to review all providers with access to HEFCE funding using a single review method, which can be varied according to institutional circumstances (for example, whether or not an institution has degree-awarding powers). In developing these recommendations, we have taken steps to ensure, not only that enhancement activities continue to comprise a major part of the risk-based quality assurance approach, but that students continue to play a central role in the quality assurance and improvement of their education.
7. In summary:
- We will continue to meet our statutory duty to ensure the regular assessment of quality and standards in all the institutions we fund, through the existing but strengthened method of Quality Assurance review known as Institutional Review.
- Greater transparency will be achieved by asking the QAA to publish a rolling programme of reviews on its web-site, which clearly indicates when a provider’s next review is due to take place; institutions will not be assigned to particular categories.
- We are asking the QAA to focus its efforts where they will have the most impact, by tailoring external review to suit the circumstances of individual providers (for instance, by adjusting the frequency, nature and intensity of reviews depending on the provider).
- Rather than asking the QAA to refine its review methods through the establishment of a core and module approach (with modules for particular types of provision which carry greater risks), we will ask the QAA to no longer undertake separate reviews of collaborative provision, and to work towards an integrated review method for all providers of HE. Such a review method should take sufficient account of the circumstances of individual providers, including whether or not a provider has degree awarding powers, and the nature of its partnership arrangements.
- We are asking the QAA to discontinue any form of mid-cycle review, given that there are already safeguards, including the QAA’s concerns scheme, which allow it to initiate work with institutions that have issues to address between reviews (see paragraph h. below).
- We will ensure that for those institutions with a longer track record of successfully assuring quality and standards, the actual period between reviews is set at six years (that is to say reviews will take place in a six-year ‘cycle’). Specifically, we will ask the QAA to ensure that it does not schedule any reviews in a shorter cycle during the transition period to the new approach.
- We will ask the QAA to review those providers with a shorter track record of assuring quality and standards at a more frequent interval of four years ( that is to say a four year ‘cycle’).
- We will seek to ensure that failures in standards and quality between scheduled reviews are addressed through continued application and promotion of the QAA’s concerns scheme.
- Rather than implement the proposed annual review of data, we will ask the QAA to take greater account of publicly available data and information in its review methods, for example, through the institutional self evaluation document, the student written submission, and its own concerns scheme. HEFCE will continue to use established processes for monitoring the risk profile of institutions, which draw on the accountability information that we routinely collect.
- We will ensure a strong approach to enhancement by retaining the new judgement on the enhancement of student learning opportunities and the thematic element of the Institutional Review.
- We will ensure that students continue to be at the heart of the process, in part by keeping the review cycle to a maximum of six years, enabling their input to be considered at least as frequently as it is in the current six year cycle. We will also ask the QAA to continue to encourage providers to engage with students as partners, as part of a continuous process of enhancement, and ensuring that safeguards are in place as appropriate, through the QAA and the Office of the Independent Adjudicator.
- The QAA will consult on a revised handbook for this more risk-based review method, with the aim of implementing it in academic year 2013-14.
- We plan to undertake an independent evaluation of the revised approach in 2015-16, once it has been in operation for two years.
8. No immediate action is required, but institutions may wish to familiarise themselves with the key recommendations of the risk-based approach set out in this document, ahead of the QAA consultation on a draft handbook for the new approach. The consultation will open in winter 2012, on the basis of HEFCE’s letter of guidance to the QAA on how to take forward this more risk-based approach to quality assurance.
9. The Department for Employment and Learning has considered the findings and recommendations of this consultation, and the implications they will have for the HE institutions in Northern Ireland. They have agreed to implement any changes to the current Quality Assurance process in line with the recommendations, and will work with HEFCE and QAA to agree the way forward. However, as HE provision in further education colleges in Northern Ireland is quality-assured through the QAA’s Integrated Quality and Enhancement Review process, any proposed changes to a more risk-based quality assurance process will not apply to further education colleges in Northern Ireland.