Unscheduled investigations of standards at universities could be triggered by indicators including poor student satisfaction survey scores, graduate employment data and low levels of "professional accreditation" of teaching staff, England's funding council has proposed.

The Higher Education Funding Council for England outlined the plans in a consultation on the new risk-based quality-assurance regime, scheduled to take effect in 2013-14.

The consultation, published on 8 May, follows the government's higher education White Paper, which announced a new regime giving "power to students to trigger quality reviews where there are grounds for concern, yet cuts back the burden of review for high performing institutions".

However, Hefce has resisted the White Paper's suggestion that full institutional reviews by the Quality Assurance Agency - to which universities are subject every six years - may no longer be a requirement for those with a reliable track record of quality assurance.

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Roger King, a research associate at the London School of Economics' Centre for Analysis of Risk and Regulation, characterised Hefce's "rejection" of the plan to remove institutional review - a plan "vigorously promoted by some institutions" - as "an important development".

The consultation instead proposes that all universities will remain subject to QAA institutional review at an interval of between six and 10 years, and seeks to canvass opinions on the appropriate time frame.

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But Hefce warns that even 10 years could leave English universities outside European quality assurance standards, which are "important for the reputation of [a] country's higher education overseas".

In line with the White Paper, the consultation outlines plans for out-of-cycle QAA investigations at an institution or department. The consultation says these could be triggered by clusters of complaints from students to the QAA or the Office of the Independent Adjudicator.

In addition, there will be "an annual process for scrutinising key data and information which could prompt an earlier than anticipated investigation by the QAA". Such data analysis is likely to be based on three years' average data and would be carried out by an internal Hefce group and an external review panel.

NSS is a 'reasonable indicator'

Key data might include the National Student Survey, the consultation says. "While not without its limitations, the NSS is a valid instrument for considering student satisfaction in relation to the student experience, which itself is a reasonable indicator of quality," the consultation states.

Other sources cited in the consultation include Higher Education Statistics Agency indicators on dropout rates, and data from the Destination of Leavers from Higher Education survey, as well as the issue of whether there is "a significantly smaller proportion of accredited teaching staff than in the rest of the sector".

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Although there would be "a lot of doubt about the validity of some of these indicators", Professor King thought the QAA would "tread very carefully" and give "strong warning signs" before an investigation was triggered.

However, Roger Brown, professor of higher education policy at Liverpool Hope University, said: "Annual data review adds yet another layer of complexity, and very little of the data concerns quality."

On the risk-based regime in general, Professor Brown said "it would take a Jonathan Swift to do justice to the irony of the government introducing a risk-based system of regulation just as the risks to individual institutions are being increased - by the government".

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Professor King said Hefce's proposal of mid-cycle investigations "provides at least some confidence in the new lighter touch regime. Certainly it is more acceptable to institutions than short-notice audits - an alternative method of accountability in such circumstances.

"But in our riskier climate, these mid-term belts and braces arrangements must be more than ceremonial flourishes if public confidence is to be retained."

The consultation proposes two routes for monitoring and review: Route A for providers that have not yet undergone two external institution-wide reviews and Route B for providers that have undergone two such reviews.

Hefce says that for Route A, which would include most private providers and further education colleges new to higher education, it "would not envisage" review intervals "being more frequent than every four or five years, or less frequent than six".

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Route B would include universities, where the proposed review interval is less frequent at six to 10 years.

john.morgan@tsleducation.com.