Dear Vice-Chancellor or Principal
Updating HEFCE’s policy for addressing unsatisfactory quality in institutions: Outcomes of consultation
1. This circular letter sets out the outcomes from the recent consultation on a draft revision of HEFCE’s policy for addressing ‘unsatisfactory quality’ in institutions. It accompanies the final version of the policy, ‘HEFCE’s policy for addressing unsatisfactory quality in institutions from 2013-14’ (HEFCE 2013/30), which will apply from October 2013.
2. In ‘A risk-based approach to quality assurance: Outcomes of consultation and next steps’ (HEFCE 2012/27), we indicated that the unsatisfactory quality policy would need to be updated in line with the amended method of quality assurance review. The revised policy will apply from the start of the risk-based Higher Education Review method in 2013-14. It will be invoked when an institution receives a published judgement of ‘does not meet UK expectations,’ or when an institution fails to make the necessary improvements through the Quality Assurance Agency for Higher Education (QAA)’s follow-up process following a published judgement of ‘requires improvement to meet UK expectations’.
3. The policy is based on the principle that any institution that receives a published unsatisfactory judgement (‘does not meet’ or ‘requires improvement’) through the QAA Higher Education Review should have two opportunities to make the required improvements; firstly through the QAA’s review follow-up process, and then if necessary through a process lead by HEFCE. The number of opportunities must be limited to protect the student interest. In line with the principles of our risk-based approach to quality assurance, the unsatisfactory quality policy is designed to be responsive and proportionate to institutional circumstances, to give greater weight to the student interest and to protect the reputation of individual institutions and the sector as a whole.
4. Prior to inviting comments on the draft policy, we discussed the policy with officers from the QAA, Universities UK, Guild HE, the Association of Colleges and the National Union of Students; we later discussed with them the consultation outcomes and subsequent adjustments to the policy. The consultation was also discussed by our Strategic Advisory Committee on Teaching Quality and the Student Experience.
5. We received 15 responses to the wider consultation, ‘Updating HEFCE’s policy for addressing unsatisfactory quality in institutions’ (HEFCE Circular letter 15/2013). Of these, five stated that they were happy with the approach and had no further comment, while the other 10 suggested areas where they felt the policy required further clarity or consideration. Annex A gives a detailed analysis of the consultation responses and how they have informed our decisions.
6. From the relatively low response rate, and in light of our prior discussions with a number of bodies, we must presume that non-respondents had no particular suggestions, comments or objections, and were broadly satisfied with the revised policy.
7. Overall there was broad agreement with the approach set out in the draft policy. Areas indicated as needing further clarity or consideration included; who the policy should apply to, when it should apply, and the details of HEFCE’s involvement and actions we might take. We have made some small adjustments in detailed aspects/explanations of the original proposal to respond to these suggestions and believe the policy has been approved as a result.
8. The QAA will issue an addendum to the Higher Education Review handbook by January 2014 (when the first Higher Education Reviews are due to take place), so that it accurately reflects the revised unsatisfactory quality policy.
9. The policy up to and including the academic year 2012-13 is described in the operating framework for funding and regulating higher education in England. The operating framework will be updated to reflect the 2013-14 policy.
10. HEFCE’s unsatisfactory quality policy does not apply to alternative providers, as we do not have a direct relationship with them. We understand that the Department for Business, Innovation and Skills is currently developing an equivalent process for alternative providers.
11. A further update to the unsatisfactory quality policy may be required for August 2014, to reflect regulatory reforms; in particular a new HEFCE Financial Memorandum, and separate terms and conditions of designation to access student support for of HEFCE-funded universities and colleges (see ‘Higher education regulatory reforms’). We would not expect to consult separately on such updates to the unsatisfactory quality policy, because any changes will have been fully considered through the respective consultations on the new Financial Memorandum and the terms and conditions for designation.
Interim Chief Executive