left to my own devices – occasional thoughts on higher education

One of the dogs that didn’t seem to bark (at least explicitly) in the recent OfS consultation on its strategy for the next five years was postgraduate provision.

It’s clear in HERA that OfS’s responsibility is for all higher education students and education provision, undergraduate and postgraduate, but sometimes it hasn’t felt that way.  OfS’s pre-2024 tendency to focus on the bête noir de jour of the previous government often seemed to lead it down an undergraduate road: e.g. concerns about grade ‘inflation’ that only ever related to the proportions of firsts and upper seconds awarded to undergraduates, with little evident attention to postgraduate classification.

equality before the regulator

We can see the attention that has been paid to postgraduate education at various points in the OfS’s implementation of its regulatory framework: for example postgraduate continuation, completion and progression metrics and thresholds are clearly incorporated under the B3 registration condition; and there are specific OfS initiatives relating to postgraduates (e.g. its funding for postgraduate conversion courses in AI and data science; increasing BAME access to research degrees).

At the same time though, it’s difficult to escape a sense of a tendency for postgraduate provision to be somewhat in an undergraduate shadow from an OfS perspective.

below the surface

Although this is no longer the case, OfS used to maintain that its Regulatory Framework met the requirements of the European Standards and Guidelines for Quality Assurance.  A key plank of the ESG is the need for regular cyclical review of provision, and OfS would point to TEF when this issue was raised despite TEF being entirely undergraduate in focus.

There are clear gaps in oversight of postgraduate provision, due to the lack of postgraduate equivalents for the NSS.  OfS has piloted a taught postgraduate survey, but there is still no sign of any sustained movement in this direction (despite the fact that it’s clear that relatively senior voices in OfS have advocated strongly for this). And no signs of such a survey for research degrees.  AdvanceHE continues on with the PTES and PRES, but the absence of postgraduate surveys equivalent to NSS is notable.

And in the first round of the ‘boots on the ground’ quality assessments there were 11 investigations, only two of which touched on postgraduate provision.  It’s a similar story with the B3 investigations: only two out of the 12 published so far addressed taught postgraduate issues.

the consequences of scale

Of course it could be argued (and I’m sure OfS would) that they operate a risk-based approach so the focus on undergraduate provision reflects where the risk has been identified.

However, there is potential bias against looking at postgraduate provision given that in these rounds of investigations OfS ‘focused on institutions with larger populations, both of students studying the subjects in question, and in terms of overall student numbers’ (OfS Insight Brief, p.3).

There are lots of postgraduate students, but fewer taught postgraduates (2022-23: 760K) than undergraduates (2022-23: c.2.9M) and many, many fewer research students (c.124K). There is a danger that risk-based quality assessment concerned with identifying the risks where ‘more students would be at risk from any issues quality’ (OfS Insight Brief, p.3), while being understandable itself risks paying too little attention to postgraduate provision.

It feels that the most significant risk is that, given its much smaller scale in terms of student numbers, it is research degree provision that slips through the net.

the smallest fish

The dual, liminal nature of research degrees is so well-recognised that it has become a cliché.

Typically this discussion focuses on the various dimensions of whether those working towards research degrees should be regarded as students or staff.  But it also applies to academic governance, oversight and quality assurance, where research degrees tend to sit between the major institutional pillars of education and research.  Shifting between these two islands.

Of course research degrees have always (in my experience) been a responsibility of a Senate, but below that I’ve seen multiple approaches.  Research degrees have been entirely the responsibility of an institution’s Education Committee.  Or its Research Committee.  Or a distinct Graduate School Committee reporting to Senate.  Most often I’ve experienced dual lines of responsibility to Education and Research committees, with different universities having distinct splits of responsibilities with varying (both in content, and in plausibility) rationales for their split.

This location of responsibility for research degrees betwixt and between education and research structures and processes at institutional level is mirrored nationally.

locations and currents

While it’s clear that under HERA OfS’s remit extends to postgraduate provision including research degrees, and UKRI is keen to emphasise that it is a funder not a regulator, the reality feels less clear cut.

The agenda on research degrees is clearly being set and driven by UKRI, so that while the regulatory responsibility for research degrees sits with OfS it feels that the strongest currents are those pulling this provision towards UKRI.

where we were and where we are

For example, OfS’s B conditions on academic quality and standards apply to research as well as taught degrees, and someone at OfS has taken great care to ensure that for the qualitative B condisions and their underlying guidance [paras. 9c, 10e, 11c, 31e, 52h, 54c] examples are included relating to research degrees.  It is interesting, however, to contrast this aspect of the regulatory framework for research degrees to that which applied before OfS through the UK Quality Code maintained by QAA.

The section of the UKQC relating to research degrees had its genesis in the mid noughties, when after some sector in-fighting the research councils, HEFCE and QAA agreed that QAA’s requirements in this area (first a chapter in its Code of Practice, then a section of the UKQC) should be the single regulatory reference point (thereby abandoning plans for a separate set of HEFCE/ research council requirements and embedding the research council’s minimum standards for research degrees in the QAA Code).

Even allowing for OfS’s claim that its outcomes-led method is a difference of type rather than kind from the approach previously adopted by QAA, the differences between the two are still striking. It is far more difficult to relate OfS’s B conditions to research degree programmes, than it is the bespoke requirements of the various iterations of the QAA’s research degree requirements.

Additionally there is little in the OfS guidance on the B conditions that help make that translation of these requirements to research degrees (and this isn’t only because this guidance is written in that distinctive OfS way of setting out practices that are likely to be problematic in meeting the condition, rather than guidance on how the Condition might be met).  By contrast, all the iterations of QAA’s research degree reference points meet this need (though I should declare an interest here, as a member of the writing group for the current UKQC Advice and Guidance: Research Degrees).

the strongest current

This creates a gap in providing clear regulatory requirements for research degrees expressed in ways that support their implementation for this provision, and it’s possible to view UKRI as taking steps to fill this.

For example in January 2024 UKRI published its Statement of Expectations for Doctoral Training.  In the new OfS regulatory environment this statement feels sets out requirements that only apply to UKRI-funded students, but still sets a frame for research supervision more broadly.

This perhaps reflect the strength of the UKRI currents in other aspects of research degree provision, so that it feels that it is, de facto, filling a regulatory space to a notable extent.

For example, the fee level UKRI sets for home research students applies only to the students they fund, but it still exerts significant influence on the fee levels set for all home research students.  And either in their writing or implementation, and either consciously or unconsciously, institutional approaches to managing research student progress (e.g. around periods of registration, leaves of absence, extensions etc.) for all research students, often seem heavily influenced by the approaches required by UKRI for the students it funds.

And of course UKRI’s work on the New Deal for Postgraduates is having an impact that will be felt well beyond those students that UKRI funds.

go with the flow?

In that context, the currents pulling research students towards research rather than education at time feel irresistible.  While it feels that unlikely to lead to change in formal regulatory responsibilities at national level, individual universities need not follow the national model.  Perhaps the time has come for more universities to recognise the strength of the currents, and rather than leave research degrees between two islands to give them a permanent institutional home on the island of research.