Universities UK [UUK] has today [Tuesday 15 March 2022] responded to three
consultations launched
by the Office for Students [OfS] on 20 January 2022.
The consultations cover new approaches to assessing quality by
looking at student outcomes – for example, how many graduates
complete courses and what jobs they go into – as well as the
Teaching Excellence Framework [TEF], and new ways for the OfS to
use data and indicators to make judgements and inform regulatory
action.
UUK’s responses highlight the importance of regulation being
proportionate to risk. Protecting students is essential and so is
ensuring that universities have the time they need to focus on
teaching, assessment, and student support.
There is a danger that narrow definitions of quality and good
outcomes will discourage innovation and penalise universities
working with students from disadvantaged backgrounds or on
non-traditional courses.
UUK is asking the OfS to consider the wide range of contributions
and good outcomes that universities support, and to consider
student views on what makes a university degree valuable to them.
UUK has identified five main asks for each consultation, detailed
in the attached document.
Central asks from UUK’s responses to the three consultations
include the following:
- We want to see a more well-rounded approach to
measuring quality and value. ‘Graduate jobs’ are
difficult to define and the OfS should also reflect graduate
views of their own success. We have recently published a
newframework to assess the
value of university courses to students and society.
- We welcome the idea of using context when
setting thresholds to evaluate student outcomes such as
employment, however this needs to be applied
consistently. The OfS should consider
geographical labour markets, student voice and opinions as forms
of context.
- The OfS should not publish data or indicators unless it can
be confident that it can contextualise the information in
ways that are clear and accessible for
a public audience.
- The OfS should take this opportunity to redefine what
the TEF is and to use new award names
to make a clear break with the previous
system. Calling the new rating category
‘requires improvement’ incorrectly implies that there is a
regulatory requirement to make improvements. This could unfairly
undermine the world-class reputation of UK universities.
- The proposed timeline for submissions to the TEF must
be extended. We would support a spring window for
submissions as this will allow universities time to review their
data and for staff and students to engage in the process. The
window for submissions should be a minimum of three months.
- The OfS should not apply the new proposed regulatory
measures to new shorter courses and ‘step-on’, ‘step-off’
modules developed as part of government plans for the
Lifelong Loan Entitlement. We need to see data
on these courses and modules before they can be assessed
appropriately.
Professor Steve West CBE, Vice-Chancellor of UWE Bristol
and President of Universities UK, said: “I am proud that
our universities have a strong track record of delivering high
quality courses which equip students with the skills and
knowledge they need for their futures.
“This high quality must be consistent across each university and
every course, and we support the OfS’s mission to protect
students and strive for continuous improvement.
“It is also crucial that the regulatory approach is
proportionate. University staff must not be overburdened with too
many administrative jobs relating to maintaining quality and
value but which ironically take their attention away from
teaching, assessment, and student support, all to the detriment
of students.
“Equally, universities should not be penalised for their efforts
to widen access to higher education by working with disadvantaged
students, especially at a time when government is seeking to
increase social mobility through the levelling up agenda.
“We will continue to work collaboratively with the OfS to
encourage a proportionate approach to regulation which is in the
best interests of students and universities.”
ENDS
Notes
- A summary of UUK’s response to the OfS consultations on
student outcomes, TEF, and the construction of indicators is
attached to this email. The summary and responses are also
available on our website.
- The deadline for responses to the three consultations is 17
March 2022.
