left to my own devices – occasional thoughts on higher education

Photo by Unsplash from Freerange Stock

In the very first episode of Yes Minister, the newly appointed Minister for Administrative Affairs is somewhat taken aback by his Permanent Secretary’s apparent support for, and efficiency in supporting, his Open Government initiative; support extending so far that the Permanent Secretary has a White Paper on this topic waiting for the Minister on the latter’s first day in post.

Of course this is part of a blocking strategy by the civil service. And the first line of this defence is later described by the Permanent Secretary to one of his more junior colleagues:

I explained [to the more junior colleague] that we are calling the White Paper Open Government because you dispose of the difficult bit in the title.  It does less harm there.

Jonathan Lynn and Anthony Jay ed., The Complete Yes Minister: The Diaries of a Cabinet Minister by the Right Hon. James Hacker MP (London, 1984), p.21

For some reason I find it hard to suppress the memory of that line, whenever I think of OfS.

an office for …

That’s (perhaps) a little unfair. At the same time, though, there was a point when OfS almost appeared to be living down to the Yes Minister-style perception.

One of the odder events in the recent politics and regulation of English higher education (and it’s a pretty competitive field) came in 2023. Members of OfS’s Student Panel appeared before the inquiry into OfS by the House of Lords’ Industry and Regulators Committee, and reported to their lordships that members of that Panel had essentially been threatened by senior staff at OfS for expressing views contrary to those OfS.

That was the product of a particular political time and place (an advantage of now having a government that’s not very good at politics, is that it makes naked political capture of a regulator less likely), both of which have now changed.

But while it’s easy to exaggerate the extent to which OfS has failed to live up to its name, it’s fair to say that within the sector, among both students and providers, there has been a persistent, pointed and well-founded questioning of how effectively if is for students.  Last year a perceptive and insightful post by Paul Ashwin argued that, more subtly (not difficult) than came to light in 2023, OfS was still ‘ventriloquising the student interest’ in order to underpin pre-determined government priorities. And, some us thought, a few of OfS’s own agendas.

must do better; fit for the future

There are many aspects of this issue, and both the report of the House of Lords’ Industry and Regulators Committee, and the subsequent Independent Review of OfS undertaken by Sir David Behan for the Department for Education, had much to say on the student interest, voice and engagement.

As well as his report including a section on regulating in the student interest, Behan also picked up a further aspect of student voice and involvement when he turned to OfS’s approach to regulating academic quality and standards, recommending that [p.43]:

the OfS should seek to build upon areas of good practice in which students are involved as lay experts. Serious consideration should be given to expanding student involvement in quality assessments and investigations as a mechanism for strengthening the student voice in the OfS and its regulation. This would build on the good practice of the inclusion of student submissions in APPs and the TEF, and student membership of the TEF panel, which the review heard function very effectively.

While this recommendation was welcome, locating the logic for it in the success of APPs and TEF was, at best, suggestive of a historical blindspot on Behan’s part.  At worst it suggested a bias towards the body which Behan was reviewing.

Harsh?  Possibly.  But also fair.

history

By the time OfS was established in 2018, never mind when Behan was writing in 2023, student involvement as lay experts in quality assessment had established itself as a sector norm.

QAA had recognised students as peers with a significant and valuable contribution to make to external quality reviews back in 2009, making the inclusion of student reviewers on peer review teams standard across its review and audit methodologies.

Having started reviewing for QAA in 2011 I’ve never been on a QAA review team that did not include a student reviewer. I’ve been fortunate to work with some truly outstanding reviewers, who brought commitment, expertise and insight to their work in the same way as any other review team member.

And of course student reviewers remain the norm in the national higher education quality frameworks in Scotland and Wales; are required on teams carrying out Educational Oversight Reviews of private higher education providers on behalf of the Home Office; and are a norm across Europe, with Standard 2.4 of the European Standards and Guidelines for Quality Assurance in Higher Education stating that ‘external quality assurance should be carried out by groups of external experts that include (a) student member(s)’.

The lack of student reviewers on OfS’s quality assessment teams wasn’t, as Behan seemed to imply, a matter of not yet taking forward learning from APP and TEF on the value of student reviewers.  It was a deliberate break by OfS from longstanding effective practice, and sector norms.

the future?

Which brings me to the OfS consultation on its future approach to quality regulation, which includes the regulator’s response to this recommendation from Behan.

The consultation waxes almost lyrical on the role of students in TEF: the value of the independent student submissions is highlighted; provisions proposed to ‘gather independent student output’ where a provider’s student representative structures ‘are less formal or less well developed’; and student assessors are retained as a key element of TEF.

The contrast with the consultation’s proposals on student involvement in the non-TEF forms of quality assessment is striking.

Here we get two short paragraphs telling us that ‘student views form an important part of other OfS quality assessments’.  But not as assessors/reviewers.  No, students aren’t regarded as peers contributing to the consideration of evidence and the making of judgments.  Students merely provide evidence through meetings between the OfS team and the student’s providers.

history repeated

The situation remains as it has been to date under OfS, which when I was writing about the first round of ‘boots on the ground’ quality assessments two years ago I described as:

Students’ interests are meant to be at the heart of OfS’s work, and by extension of this process. Yet their role in quality assessment reviews is as the congregation responding to the prompts of the academic priesthood that is the assessment team. Students watch from the other side of the screen, while the process of making quality assessment judgments is performed by a team with no student membership. The student voice has a defined and limited place, and where judgments are made the direct student voice has been silenced.

In the current OfS consultation, Behan’s recommendation has essentially been ignored.

isolation

This is a prime example of the anything-but-splendid isolation in which OfS often likes to sit.

Separating itself and English higher education from the significant evidence, over a prolonged period of time and in multiple settings, of the value that student reviewers bring to external quality review.  Putting distance between itself and practice in the rest of the UK and in Europe.

Alone again.  Though not naturally, as this is a choice.  And one that becomes ever more mystifying, and damaging, the longer it goes on.