Excessive admin will take focus away from teaching, universities warn regulator
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 new framework 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.”