left to my own devices – occasional thoughts on higher education

Working in gradually more senior professional services roles in higher education, in turn leads to spending increasing time working with multiple senior academic leaders.  And as with any other type of organisation or sector, these senior leaders all have distinctive approaches that become clear sooner or later.

With one such senior academic leader whom I worked with, one aspect that became very clear very quickly was that they operated a relatively rigid three-point scale for expressing their displeasure/discontent with something.

Level 1 was to voice ‘surprise’; not a shot across the bows, more a glancing blow.  The second was ‘disappointment’, which was less an expression of a feeling than a direction to go back and think again and think better.  The final level was the expression of ‘dismay’, at which point the implication was that you were being left in the metaphorical room with a metaphorical glass of whiskey and revolver.

And this has come back to the forefront of my mind over the last few weeks as I’ve thought about OfS’s current Consultation on the future approach to quality regulation.

one and one make …

I wasn’t quite sure how to characterise this set of proposals.

Initially it brought to mind an episode from the classic era of The Simpsons, where Homer’s successful, car manufacturer-running and long-lost brother decides that the future of his company should be bet on Homer’s ‘insight’ into this sector and places all the company’s chips on a car designed to Homer’s specification.  With predictable results:

It’s a tempting analogy, even down to allocating the roles of Homer’s brother, Homer and the new car he designs to players and proposals in the current development of quality assessment in English higher education.  Very tempting.

Ultimately though, something a former colleague said to me a lot of years ago felt as though it fitted better.

This was when the university at which I was then working had two departments that were falling (far) short of expectations, and the solution to this was decided to be merging the two into a single school.  And the colleague in question said that taking two broken things and putting them together, didn’t seem like the best approach to creating one thing that worked.

And for me, that hits the nail on the head with OfS’s proposals for (yet another) revised quality regime for English higher education.

no surprises

What’s currently being consulted on is the product of the Behan review’s recommendation last year ‘that the OfS’s quality assessment methodologies and activity be brought together to form a more integrated assessment of quality’ [Recommendation 12, p.17].

It’s very tempting to delve into the detail of the current OfS consultation document (after all, at 105 pages there’s lot to delve into).  Many have already done this, so I’m not going to go into that level of detail here.

Instead I’m going to try to focus on some aspects of the bigger picture.  And in doing so it’s difficult to avoid a sense that what is being proposed is inadequate, as they try to make one thing that works by combining two things that are broken.

building on sand

One of these broken things is TEF.

In detail the consultation includes potentially positive changes to TEF (e.g. the changes to the treatment of Graduate Outcomes data), and some definitely bad things (e.g. achieving the almost impossible task of making Rio 2016 Medals approach to TEF ratings even worse; a high bar).  But more broadly, TEF is broken.

It’s difficult to accept the consultation document’s contention that TEF has been a success.  Claims that it has led to a focus by universities on educational enhancement that would not otherwise have happened, feel like an unspoken conspiracy between a regulator determined to defend TEF and a sector making a decision to acquiesce in this for political reasons.

The TEF process makes claims about its ability to assess educational quality that can’t be sustained.  TEF has a very particular approach to defining educational quality that doesn’t correlate with the educational research.

While much of the data used by TEF is interesting, the judgments place a greater weight on this than it can bear.  It’s very difficult to sustain an argument that as an assessment TEF is ‘valid and reliable’, or ‘credible at the point of being granted and when compared to those [awards] granted previously’ (to quote Ongoing Condition of Registration B4, applied by OfS to the way that higher education providers are expected to assess our students).

Others have pointed out far more effectively and eloquently than I can, there are manifest and manifold reasons that the move to link TEF outcomes to funding only makes things worse.  In addition to which the decision to have yet another go at pushing TEF outcomes as an important source of applicant/student information remains as fundamentally misguided, misleading and as unlikely to succeed as it has always been.

the hole-y net

The other broken thing is the approach to quality assessment.

The national regulation of academic quality and standards in England is in as poor a shape now as it has been for 30 years.  The one-note approach of outcomes-based quality assessment, ignoring that intent and process are also important and cannot and should not be overlooked by any national quality assessment scheme that aspires to be fit for purpose, has failed.

It has led to instances of shockingly bad practice by some universities in respect of collaborative provision that has inflicted serious disbenefit on thousands of students, as well as seriously tarnishing the reputation and standing of the sector as a whole and resulting in the misuse of public funding.  Of course those universities that have enabled this as awarding bodies must take a significant element of the responsibility for this; but the lion’s share must be for the national regulator that has allowed this to happen on its watch.

OfS continues to double down on its outcomes-led approach to quality assessment, ignoring the need to accompany this with the type of focus on intent and process that remains standard in the other three countries in the UK and which is a key element of quality assessment internationally as set out in the European Standards and Guidelines.

This approach will continue to be inadequate. Problems (foreseen and unforeseen) will slip through the net, and as a consequence we will continue to see OfS desperately playing whack-a-mole by issuing new registration conditions (as it is now on collaborative provision) to deal with problems its chosen approach to quality assessment has not been able to prevent and/or address.

a chance missed

So to go back to where this post started, ‘surprised’ is clearly an inadequate response to the current OfS proposals to create a single integrated approach to quality assessment.

‘Dismay’ is perhaps too strong, as the proposals could have been worse and there are some positive aspects.

So, ‘disappointed’ it is.  And in a number of ways, flowing from and additional to those set out above.

One is that it’s another step forward in English exceptionalism, moving us further away from UK-wide and international norms and as a result likely to cause harm to the overall standing of UK higher education.

Another is that an opportunity to work in a co-regulatory way to end the current round of the quality wars has been spurned (and indeed a new front has recently been opened up, with OfS’s power grab last week over academic standards).  As a result the new integrated approach work, and it won’t be long before the English sector will yet again be reviewing and revising the national quality system (as we did in 2010; 2012; 2016; 2018; and 2022).

And a final one is that while this is being sold as an integrated approach to quality assessment and by implication a rationalisation of external regulation, in many ways it feels part of the broader regulatory expansion of recent years that has been furthered by the recent White Paper – as Paul Greatrix has fairly characterised it, ‘punishments will continue until morale improves’.

this has happened before; all of this will happen again

There’s a saying that history doesn’t repeat itself, but it does rhyme.

As someone moving towards the edge of my seat as the England cricket team starts another Ashes tour, I’m hoping that this isn’t true.  But then of course I remember the outcomes of the 2002-3, 2006-7, 2013-14, 2017-18 and 2021-22 tours, when the rhyming stopped only just short of repetition.

The saying is often true, and in the context of regulating academic quality and standards in English higher education this reminds me of what happened last time there was a new Labour government.

In the late 1990s and early 2000s the last such new administration accelerated rather than reversed the trend to increased regulation of higher education that had occurred under its Conservative predecessor.

Increased regulation of academic quality and standards was a central feature of this, with the dual running of audit and subject review due to continue and in fact to be made more demanding on universities through the new subject review methodology planned for 2002 onwards.  And this was accompanied by stern warnings to the sector, e.g. warnings to universities of the need to get on board with what was happening as the sector was ‘drinking in the last chance saloon’.

However, in response to concerted opposition from universities the government ultimately reset, accepting that the regulation of quality and standards needed to be more proportionate.  Many of the external regulatory requirements were retained, but the demands were significantly mitigated – most notably the ending of subject review.

Of course history doesn’t always rhyme, never mind repeat.  After all, to return to that list of England’s cricket tours down under the one I missed out was the triumph of 2010-11 when the series of catastrophic losses was punctuated by a convincing victory.

But it’s interesting to think about what might happen over the next few years if, as I think is likely, the current regulatory approach to English higher education proves to be both overly burdensome while not actually doing the job that’s needed.

After all, remember when we were all being told that subject-level TEF was a done deal and we all needed to just get used to it …