1. This document builds on the responses to the consultation on future approaches to quality assessment in universities and colleges in England, Wales and Northern Ireland. It sets out the revised operating model for quality assessment to be implemented in England and Northern Ireland from 2017-18, the transition arrangements during 2016-17 to support such implementation, and plans for a range of pilot activities during 2016-17.
2. As part of their respective statutory responsibilities, the higher education funding bodies in England, Wales and Northern Ireland sought views on future approaches to assessing the quality of education in the universities and colleges they fund or are considering funding. The review was intended to consider what kind of quality assessment arrangements would be necessary as we look towards 2025 and the next decade of the sector’s development. The analysis of responses to the consultation revealed broad agreement with the proposals, together with a number of suggestions for refining them.
3. It is intended that the high-level elements set out in this document will be taken forward in Wales in a similar way to the approach adopted in England and Northern Ireland, but the detailed operating model for quality assessment in Wales will be the subject of a separate consultation by HEFCW under its new powers in the near future.
4. This document also sets out plans for a range of pilot activities that will take place during 2016-17 across England, Wales and Northern Ireland, and in some cases Scotland. The sector representative bodies will lead this pilot activity where it relates to the development of the external examining system.
5. Some activities in the new operating model will be undertaken by the relevant funding body. Other elements are more appropriately delivered under contract by one or more external organisations with relevant expertise and experience. We will undertake an open procurement process for these contracts through the Official Journal of the European Union.
6. As we have designed the revised approach to quality assessment, we have sought to address a number of cross-cutting issues:
- A UK-wide system – the revised approach to quality assessment provides, at the level of principle and key features, a shared approach in England, Wales and Northern Ireland. We will continue to work with the Scottish Funding Council in areas of particular UK-wide importance.
- European quality expectations – the revised operating model has been designed to be consistent with the new 2015 European Standards and Guidelines and, after further design work at a more detailed level, to meet the requirements of the European Association for Quality Assurance in Higher Education and the Register Committee of the European Quality Assurance Register.
- The role of students – The funding bodies will continue to work with students and their representative bodies to ensure that they are actively involved in designing and implementing quality assessment arrangements, and providing evidence about their own academic experiences in the context of a particular provider.
- The Home Office’s requirements – The revised operating model to be implemented in England and Northern Ireland, and the transition arrangements to be put in place during 2016-17, meet the Home Office’s requirements for educational oversight.
- The Government’s Green Paper – We continue to work closely with the Department for Business, Innovation and Skills to ensure that the quality assessment arrangements implemented by HEFCE in England align seamlessly with the Government’s proposed reforms as set out in its higher education Green Paper. The content of this document is, in part, a product of that process of work, which we expect to continue.
The revised operating model for quality assessment
7. One of the strongest and most consistent messages to emerge from the review period was that the growing diversity of providers and provision in the sector means that ‘one size’ of quality assessment can no longer ‘fit all’, and that future quality assessment arrangements should seek to encourage innovation in learning and teaching, rather than driving providers towards risk-averse activities and homogenised provision.
8. The approach for implementation is therefore designed to be proportionate, risk-based and grounded in the context of each individual provider and its students: it will target regulatory scrutiny and activity on those issues and providers that represent greater risk to the student academic experience or to the reputation of the sector as a whole. It will do this in a way that makes better use of existing arrangements, strengthened where necessary, and encourages continuous improvement within providers.
9. More broadly, the approach is underpinned by the view that ‘quality’ is an inescapable part of an overall approach to regulation that cannot in future be considered separately from the broader context in which an individual provider operates. In particular, the refocusing of regulation around the student interest demands ‘intelligent’ regulation that provides the assurances that matter to students – on degree standards, student outcomes and the academic experience – and makes it impossible to separate out scrutiny of ‘quality’ from other tailored regulatory activity and intervention.
10. We believe that this tailored approach will significantly reduce the regulatory cost and burden for many providers as it removes the need to prepare for repeated and routine ‘one size fits all’ cyclical quality reviews against the baseline requirements. It is also designed to encourage creative and context-specific approaches to the design and operation of a provider’s own quality management arrangements, rather than engendering a compliance-focused quality culture. Critically, the proposals ensure that the autonomy of providers is preserved.
11. The components of the revised operating model for quality assessment are set out in the sections that follow.
Baseline regulatory requirements
12. The set of baseline regulatory requirements will include the following elements:
- The framework for higher education qualifications in England, Wales and Northern Ireland.
- Specific elements of the current UK-wide Quality Code.
- The financial sustainability, management and governance requirements of the relevant funding body.
- The Higher Education Code of Governance, or other equivalent designated governance code.
- The expectations of consumer law as expressed through the Competition and Markets Authority guidance.
- Student protection measures as expressed through the Office of the Independent Adjudicator’s good practice framework and the Northern Ireland Public Service Ombudsman equivalent, and HEFCE’s Statement of Good Practice on higher education course changes and closures.
- The provider’s mission and strategy for its higher education provision.
13. The external reference points that comprise the baseline regulatory requirements already exist in the regulatory landscape and are developed and used by a range of organisations and bodies. It is important to note here that we are not seeking to take responsibility for these components, but to draw together the existing material that is important in assessing whether a provider is ready to enter the higher education sector, and to present this transparently and coherently for providers and for students.
14. We will work with sector and student representative bodies to convene a UK-wide standing committee to provide sector-led governance arrangements for the baseline regulatory requirements. We see this as an important element of a co-regulatory approach.
Gateway into the higher education system
15. There will continue to be a rigorous test of a provider’s readiness to enter the higher education sector. A provider will be reviewed against the baseline regulatory requirements set out in paragraph 53, and this process will include an independent peer review visit to the provider by trained academic and student reviewers.
16. The Gateway process will also fulfil a developmental function. It will identify the areas for development for a provider to progress through a developmental period (see paragraph 70) and be considered ‘established’ at the time of its next review visit. This development activity is likely to focus on the necessary steps for a provider to establish mature academic and corporate governance arrangements.
17. As now, the relevant funding body will reach a judgement about the provider’s readiness to enter the sector, drawing on all the Gateway evidence, including from the peer review visit. It will also identify any further development needed over the following years, and the support available during this period. We intend that these arrangements for entry to the higher education system be designed and operated in such a way as to avoid unnecessary barriers or bureaucracy or cost.
Developmental period: enhanced monitoring and scrutiny
18. The framework for quality assessment is designed to deliver a period of enhanced scrutiny for providers new to the system. We will avoid using the term ‘probation’ and will instead refer to this as a ‘developmental period’ of enhanced scrutiny and support for recent entrants to the sector.
19. This ‘developmental period’ will last for four years in the first instance. During this period a provider will:
- Undertake the developmental activities identified as necessary when it first entered the sector, including completing any action plan put in place at that time.
- Undergo an Annual Provider Review process, as set out in paragraph 92 in relation to established providers.
20. At the end of the four-year period, a provider will receive a further independent peer review visit to re-test the quality aspects of the baseline regulatory requirements. The relevant funding body will use the evidence from the review visit and evidence that it has collected through successive Annual Provider Reviews, to judge whether the provider’s own arrangements for safeguarding quality and standards and for providing broader assurances about its activities are sufficiently mature and reliable for it to move into a category requiring less intensive regulatory scrutiny (that is, to be deemed ‘established’).
Review for established providers
21. The revised approach to review for established providers has the following components:
- Verification of a provider’s methodology for its own review processes, as a one-off transition mechanism, to ensure that these are focused appropriately on delivering continuous improvement in the student academic experience and in student outcomes.
- An Annual Provider Review process, tailored for operation in each country, that brings together the scrutiny of data, student views and other intelligence, and the information collected through the relevant funding body’s annual accountability processes.
- A re-focused periodic Assurance Review visit, conducted by the relevant funding body, to test the basis on which a governing body can provide assurances about the provider’s activities in this area. We will put in place support and guidance for governing bodies as they undertake this role.
When investigation and intervention are necessary
22. The relevant funding body will consider and, if appropriate, act on concerns about the integrity of standards, or the quality of the student academic experience. Such concerns can be reported directly to the relevant funding body by stakeholders, including external examiners, students, and other regulatory bodies. This arrangement will replace the current Quality Assurance Agency for Higher Education Concerns Scheme from 2016-17. Where further investigation is considered necessary, this will include a tailored independent peer review visit to the provider, using trained academic and student reviewers as appropriate.
23. The Annual Provider Review process operated by the relevant funding body (see paragraph 92) may also identify areas of a provider’s activities that require further investigation and, if appropriate, intervention. In these circumstances, where there is evidence that prima facie serious or material issues have not been successfully addressed in a timely manner by the provider, the same process for investigation will be adopted.
Degree standards and their reasonable comparability
24. We will continue to use the Framework for Higher Education Qualifications as a clear written expression of academic output standards. It will be a component of the baseline regulatory requirements (see paragraph 53) and will continue to provide a shared approach to setting standards across the UK system at threshold level.
25. We also wish to investigate a range of approaches designed to improve arrangements for the maintenance of degree standards and their reasonable comparability. In particular, we believe that it would be beneficial to the sector and its stakeholders to consider further strengthening the external examining system. We believe that this would enhance the role of the external examining system as part of the future quality assessment system, and would be highly desirable in its own right. However, we wish to develop this area in a way that is credible to the academic community and respects the autonomy of providers.
26. We will therefore support the sector representative bodies to explore different approaches to training external examiners. The focus of the training will be to ensure that external examiners are clear about their role and have the requisite technical assessment skills. They will then be better able to provide reliable judgements about the standards set by institutions and the measurement of student achievement against them, such that standards are maintained over time and are reasonably comparable.
27. We will also support the sector representative bodies to explore different approaches to the calibration of standards. The intention is to establish a simple mechanism to bring together examiners from a subject community to compare their students’ work and to judge student achievement against the standards set in order to improve comparability and consistency.
28. We will also commission the sector representative bodies to undertake detailed research into the range of classification algorithms currently in use, and to determine a sensible range of possible algorithms according to the desired pedagogic and other outcomes.
International aspects of quality assessment
29. A UK provider should remain fully responsible for academic output standards, student outcomes, and the quality of the student academic experience, wherever its students are based or however they study. In practice, this means that the arrangements set out in this document – at the entry Gateway, through the development period, and for established providers – will apply on exactly the same basis to programmes delivered internationally, whether with a partner or not.
30. We have also concluded that it would be helpful to develop our understanding of the maturity of the quality assessment arrangements in other countries, and the extent of the local scrutiny that UK providers undergo when operating in these jurisdictions. We therefore intend to develop further strategic engagement with governments and agencies in countries where UK providers are active. This activity will provide a better understanding of quality-related developments in specific countries, and a platform for developing mutual recognition of quality assessment arrangements.
31. In addition we will preserve a number of aspects of the current arrangements for the review of UK providers’ transnational education activity.