The USA had embarked on a military campaign based on emotion and conviction, with insufficient critical thought and planning. After initial apparent success, celebrated hubristically, it found itself in a quagmire; paying a much heavier price than it had thought possible: and with no clear exit strategy. Unable to secure victory; unable credibly to claim victory and end the campaign; unwilling to accept the strategic mistake and withdraw.
No not, USA-Iran in 2026. USA-Iraq in 2006. (Though there are of course other candidates in addition to these two).
all that glitters
By 2006 the initial, near-instant success of the ‘Race to Baghdad’ had given way to an insurgency that constituted a brutal civil war for which the US and its allies were ill-prepared or -equipped. And not least in terms of battlefield tactics. So in this year the American army started to develop a new manual on how to approach counter-insurgency. At one of the initial meetings for this work, a US Army Colonel:
kicked off the discussions by handing out more than one hundred small, hard pieces of green stones with red veins in them. It was coprolite. ‘They’re pretty, polished, like gem stones’, he told the audience. But, he explained, coprolite is actually fossilised dinosaur excrement. This, [he] warned, was what he didn’t want the new counter-insurgency manual to be: a new polishing of old c**p.
Thomas E Ricks, The Gamble: General Petraeus and the Untold Story of the American Surge in Iraqi (London, 2009), p.25
For some reason that story came to mind when OfS released the outcomes of its initial consultation on the next iteration of its approach to quality regulation.
who’s counting?
This was almost exclusively reported as a ‘next TEF’ issue, but as the title suggests goes much wider. In July 2024 the Behan Review recommended ‘that the OfS’s quality assessment methodologies and activity be brought together to form a more integrated assessment of quality’ [p.17]. And this is the response to that recommendation: the next iteration of TEF and quality assessment, both of which have changed so frequently over the last year that we probably now need to start numbering them in a similar way to smartphone operating systems.
TEF1.0 was the exercise in 2016 that none of us knew was happening, using the last round of QAA institutional review outcomes. Then in 2017 was TEF2.0, the first time providers made submissions for the 2016 Rio Olympics inspired TEF awards; followed by further iterations in 2018 and 2019 under a modified version of the process – TEF2.1. At the same time OfS was working on the beta version of TEF3.0, piloting subject level assessment to run alongside provider-level assessment, only for problems with the development causing multiple postponements and its ultimate scrapping. Instead in 2022 and 2023 we got TEF4.0, a modified (notably, but not extensively) version of TEF2.1. So I think that what we’re looking at now is TEF5.0.
QA1.0 emerged in 2018 with the publication of OfS’s Regulatory Framework setting out the B Conditions for academic quality and standards, linked to a heavily revised UK Quality Code driven, despite its UK-wide role, by the demands of OfS as the English regulator. Despite this, and having taken QAA metaphorically hostage as England’s Designated Quality Body (DQB), this was replaced in 2022 by a completely revised set of B Conditions; not just a rejection of the UK Quality Code, but also a full-frontal assault on it (‘providers should note that there are likely to be some parts of the [UK Quality] Code which would lead to practices we consider non-compliant with our regulatory practices’ [p.104]). Followed the next year by QAA needing to walk away as DQB as OfS’s regulatory approach in England did not meet international standards. There must be something about OfS and football world cup years, as now in 2026 QA2.0 will be replaced by QA3.0.
That’s a lot of polishing. The problem is that all the polishing in the world can’t change the nature of the raw material being buffed.
the wrong turn
OfS has set itself to be an outcome-based regulator, and nowhere is this more evident, or more flawed, than in respect of academic quality. Both TEF and its approach to quality assessment have qualitative elements, but the emphasis is over-whelmingly on quantitative outcomes data: NSS, continuation, completion, graduate destinations. Yes we have TEF Assessors, quality assessment teams and the submission of additional evidence by providers to supplement the quantitative indicators; but it is those indicators that set the terms of the engagement and drive the processes.
Of course the pre-2018 approaches to external regulation of academic quality and standards placed much too little emphasis on this outcomes data. However, the pendulum has now swung far too far the other way. Regulatory interventions and judgments are essentially led by quantitative data that is far too limited and out-of-date to carry the weight that is being placed on it in respect of either regular quality assessment or TEF. The OfS’s data-based panopticon is fundamentally flawed.
In respect of quality assessment, the extent to which OfS is unable to use the data available to it to capture and address potential quality and standards issues in a timely way is evident whenever a report of a quality assessment investigation is published.
As for TEF judgments, I suspect that across the sector a majority would say that they had confidence in the robustness and consistency of TEF judgments. And of course, under the new proposals those TEF judgments matter much more. To date the practical impact of TEF judgments was limited to institutional bragging rights, which were (rightly) largely ignored by applicants. Now, though, the implications will be a cap on student number growth and the right to apply ‘for kinds of funding in the future’ [p.52]; with the further prospect of undergraduate home fee caps being determined by TEF outcomes, should the government ever get around to following through on its commitment in last November’s Skills White paper [p.67] to link between TEF outcomes and the undergraduate home fee cap.
what is to be done
(To borrow a phrase).
A reset. An acknowledgment that the current approach to quality assessment (including TEF) in England is fundamentally flawed.
What is needed is a shift that recognises, as Vikki Stott observed in a post this summer, that ‘internal quality processes are the only mechanisms that help students in real time’. That the current approach of OfS, as Stott also stressed, are ‘explicitly retrospective … the regulatory system cannot, by design, respond to a quality problem that emerged last Semester. Only you [the provider] can’.
Deeply unfashionable as it is, internal quality processes matter. A lot. And given that they matter, it as an abdication of responsibility for an external regulator to regulate only outcomes and pay no attention to the processes by which a provider manages its academic quality and standards. There is good reason why every other country in the UK, and international standards for quality management in higher education such as the European Standards and Guidelines, pay attention to how well-designed, and effective in practice, internal quality assurance processes are. For a regulator not to do this is to demonstrate that it is does not care that providers are able to identify and address academic quality and standards issues in real time; that it only caresa about such issues after the fact.
In other words, to return to something I have written at length about before, to take forward the only integration in the regulation of academic quality and standards that really matters: the integration of the sector’s traditions of quality assessment and quality audit.
This shouldn’t be complicated. It’s a recognition of what co-regulation in this space has to mean, to be meaningful. It’s a blending of the best of more traditional approaches to quality assurance, with the need for this to be tensioned against outcomes data as in effect exists elsewhere in the UK. There is no excuse for not shifting the English sector in this direction
And it changes the raw material of OfS’s current approach for something of more value and utility. So perhaps in the future, we don’t need to do so much polishing, so often.
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