The Office for Students¡¯ plans for deciding which institutions to investigate if they fall below new quality baselines ¡°lack transparency¡±, while proposals for a teaching excellence framework (TEF) rating of ¡°requires improvement¡± should be abandoned, Universities?UK has told the English regulator.

Under plans for a revised regulatory system unveiled by the OfS, it will set numerical baselines for the proportions of each course¡¯s graduates going into ¡°managerial or professional¡± employment or?further study and for continuation and completion rates. Universities fear that institutions recruiting disadvantaged students will be penalised under the baseline metrics. Institutions falling short face the prospect of improvement notices, fines or ¨C the ultimate threat ¨C being stripped of access to?student loan funding or of university title.

UUK published on 15 March to OfS consultations on the regulation plans and on next steps for the TEF.

¡°Measuring outcomes is important but we must understand how providers achieve this,¡± says UUK in the consultation response.

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In a change to its initial plans, the OfS said it will consider institutions¡¯ ¡°context¡± if they fall below baselines, including variation in outcomes ¡°for different types of students and courses¡±. It plans to publish institutions¡¯ data and to make judgements about which institutions to investigate if they fall below baselines via an annual ¡°prioritisation¡± process.

UUK says the OfS¡¯ suggestion that the prioritisation process ¡°could change each year and be based on sampling or themes would not be proportionate¡±.

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¡°The current proposals on how the OfS will prioritise their assessment lack sufficient transparency and proportionality,¡± UUK adds. The OfS should instead focus on the ¡°most severe breaches¡±, with the prioritisation approach ¡°led by an independent process¡± including ¡°engagement from students and academic experts¡±, it says.

While welcoming the OfS decision to take context into account when setting numerical thresholds and assessing compliance, UUK emphasised that the regulator ¡°should always allow geographical labour markets, student voice and the value added measures as reasonable forms of context¡±.

The ¡°limitations¡± of the Graduates Outcomes survey that the OfS plans to use to look at proportions entering managerial or professional employment mean that ¡°weighting of this measure in final judgments should be considered and reduced in favour of other indicators and contextual information¡±, UUK says.

UUK also says the OfS plans bring a ¡°risk that large volumes of data will be published without sufficient context¡± and that contextual information should be published alongside the data.

The TEF consultation offers ¡°an opportunity to redefine what the TEF is and make a clear break with the previous system¡±, UUK says, with its preference being for ratings of ¡°commended¡±, ¡°highly commended¡± and ¡°outstanding¡±, rather than the current gold, silver and bronze.

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¡°We support the introduction of a fourth category and understand its purpose but we have significant concerns about the label ¡®requires improvement¡¯,¡± it adds.

Such a rating label ¡°could be reputationally damaging for institutions assumed to be ¡®failing¡¯ despite meeting high quality thresholds¡±, leading to a fall in student numbers, UUK warns.

¡°This will be exacerbated where the consultation proposes that the fourth rating category will be viewed as a provider not receiving a TEF award, and the tuition fee limit therefore set at a lower rate,¡± it adds, which ¡°means a reassessment option needs to be made available to providers receiving this rating¡±.

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The consultation also raises concerns about the burden of increased regulatory requirements for data.

Steve West, UUK president and University of the West of England vice-chancellor, said: ¡°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.¡±

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john.morgan@timeshighereducation.com